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 allowed the writ petition and directed that the petitioner may file a fresh application for condonation of delay under s.119(2)(b) of the Act; the respondent is directed to consider such application on its merits and in accordance with law. The court observed the statutory requirement that condonation grounds demonstrate "genuine hardship," noted prior opportunities given to the petitioner to furnish supporting documents, and recorded deficiencies in the petitioner's earlier submissions, but nevertheless permitted renewal of the statutory remedy rather than dismissing statutory relief outright. No procedural infirmity requiring quashing of the condonation process was found.
The HC allowed the writ petition and directed that the petitioner may file a fresh application for condonation of delay under s.119(2)(b) of the Act; the respondent is directed to consider such application on its merits and in accordance with law. The court observed the statutory requirement that condonation grounds demonstrate "genuine hardship," noted prior opportunities given to the petitioner to furnish supporting documents, and recorded deficiencies in the petitioner's earlier submissions, but nevertheless permitted renewal of the statutory remedy rather than dismissing statutory relief outright. No procedural infirmity requiring quashing of the condonation process was found.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
