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...
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The HC set aside the respondent's rejection of the petitioner's Form No.1 declaration under the DTVSV Scheme, 2024, holding that mandation to file the appeal online under Rule 45 did not render the manually filed appeal invalid; the appeal is to be treated as pending on the specified cut-off date for eligibility and calculation of disputed tax in terms of the Scheme. The court found the respondent unjustified in denying scheme relief and directed the respondent to process the petitioner's declaration under the DTVSV Scheme, 2024. Parties are anonymized; relief is declaratory and procedural, compelling administrative compliance with the Scheme.
The HC set aside the respondent's rejection of the petitioner's Form No.1 declaration under the DTVSV Scheme, 2024, holding that mandation to file the appeal online under Rule 45 did not render the manually filed appeal invalid; the appeal is to be treated as pending on the specified cut-off date for eligibility and calculation of disputed tax in terms of the Scheme. The court found the respondent unjustified in denying scheme relief and directed the respondent to process the petitioner's declaration under the DTVSV Scheme, 2024. Parties are anonymized; relief is declaratory and procedural, compelling administrative compliance with the Scheme.
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