Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
HC dismissed the stay application and directed compliance with the tax attachment. The respondent (CIT) ordered bank attachment of thirteen accounts; the SSC undertook that upon the petitioner depositing twenty percent of the assessed demand the accounts would be de-attached and the Bank notified. The petitioner must deposit twenty percent of the demand with the Government and forward a copy of the Challan to the AO on or before 03.10.2025; upon issuance of this order the attached accounts shall be released immediately to permit that payment. The petitioner is granted liberty to prefer an application to the CIT challenging the AO's order on the remaining eighty percent by 03.10.2025, which the CIT shall consider.
HC dismissed the stay application and directed compliance with the tax attachment. The respondent (CIT) ordered bank attachment of thirteen accounts; the SSC undertook that upon the petitioner depositing twenty percent of the assessed demand the accounts would be de-attached and the Bank notified. The petitioner must deposit twenty percent of the demand with the Government and forward a copy of the Challan to the AO on or before 03.10.2025; upon issuance of this order the attached accounts shall be released immediately to permit that payment. The petitioner is granted liberty to prefer an application to the CIT challenging the AO's order on the remaining eighty percent by 03.10.2025, which the CIT shall consider.
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TaxTMI 
TaxTMI 
of 4918 
