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...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
The HC quashed the impugned assessment order dated 16.02.2024 and remitted the matter to the 2nd Respondent for fresh adjudication after observing that the Petitioner failed to respond to the SCN dated 30.12.2023 and subsequent notices. Consistent with precedent, remand is conditioned upon the Petitioner's additional pre-deposit of 15% of the disputed tax in cash from the Petitioner's Electronic Cash Register/Electronic Credit Ledger, over and above the 10% already deposited before the Appellate Authority, such that total pre-deposit equals 25%. The 15% cash deposit must be made within 30 days of receipt of this order. Petition disposed by way of remand.
The HC quashed the impugned assessment order dated 16.02.2024 and remitted the matter to the 2nd Respondent for fresh adjudication after observing that the Petitioner failed to respond to the SCN dated 30.12.2023 and subsequent notices. Consistent with precedent, remand is conditioned upon the Petitioner's additional pre-deposit of 15% of the disputed tax in cash from the Petitioner's Electronic Cash Register/Electronic Credit Ledger, over and above the 10% already deposited before the Appellate Authority, such that total pre-deposit equals 25%. The 15% cash deposit must be made within 30 days of receipt of this order. Petition disposed by way of remand.
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TaxTMI 
TaxTMI 
of 4918 
