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...
SC upheld the HC orders condoning delay in filing tax appeals by the Revenue but found the HC's reasoning deficient and insufficiently detailed; the SC held that the HC must examine the facts pleaded in applications for condonation of delay with particularity before final disposal. Although no serious procedural or substantive error warranted interference with the condonation orders, in the interest of justice the SC directed the Revenue to pay costs quantified at Rs.25,000 to the respondent/assessees in each tax appeal before the HC and admonished that future condonation applications be decided on a detailed, fact-sensitive rationale.
SC upheld the HC orders condoning delay in filing tax appeals by the Revenue but found the HC's reasoning deficient and insufficiently detailed; the SC held that the HC must examine the facts pleaded in applications for condonation of delay with particularity before final disposal. Although no serious procedural or substantive error warranted interference with the condonation orders, in the interest of justice the SC directed the Revenue to pay costs quantified at Rs.25,000 to the respondent/assessees in each tax appeal before the HC and admonished that future condonation applications be decided on a detailed, fact-sensitive rationale.
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TaxTMI 
TaxTMI 
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