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 held that the impugned order refusing the stay application concerning demand/partial payment is cryptic and devoid of any application of mind to the specific grounds advanced by the applicant; accordingly the impugned order is set aside and the matter is remitted to the CIT (Exemption) for de novo consideration. The CIT (Exemption) is directed to frame and decide the stay application on the merits, dealing with each pleaded ground, and to pass a reasoned order in accordance with law within a reasonable time, preferably within four weeks from receipt of a copy of this order. Costs are left in the discretion of the remitting authority.
The HC held that the impugned order refusing the stay application concerning demand/partial payment is cryptic and devoid of any application of mind to the specific grounds advanced by the applicant; accordingly the impugned order is set aside and the matter is remitted to the CIT (Exemption) for de novo consideration. The CIT (Exemption) is directed to frame and decide the stay application on the merits, dealing with each pleaded ground, and to pass a reasoned order in accordance with law within a reasonable time, preferably within four weeks from receipt of a copy of this order. Costs are left in the discretion of the remitting authority.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4921 
