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 dismissed the miscellaneous application and upheld the ITAT's remand to the AO/TPO/DRP, holding that whether the assessee qualifies as a trader other than a wholesale trader depends on factual satisfaction of the two cumulative conditions in the CBDT notification dated 29.10.2015. The court observed the assessee had adduced material showing non-compliance with one condition and the ITAT had already accepted non-classification as a wholesale trader for AY 2014-15; consequently the issue is fact-centric and does not raise any substantial question of law, precluding judicial interference with the remand or directing application of a 3% tolerance.
The HC dismissed the miscellaneous application and upheld the ITAT's remand to the AO/TPO/DRP, holding that whether the assessee qualifies as a trader other than a wholesale trader depends on factual satisfaction of the two cumulative conditions in the CBDT notification dated 29.10.2015. The court observed the assessee had adduced material showing non-compliance with one condition and the ITAT had already accepted non-classification as a wholesale trader for AY 2014-15; consequently the issue is fact-centric and does not raise any substantial question of law, precluding judicial interference with the remand or directing application of a 3% tolerance.
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