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 found prima facie merit in the petitioner's challenge to the respondent's inaction on revalidation of import licences but declined to grant pre-emptory relief or issue a writ of mandamus directing revalidation. Instead, the HC directed the respondent's PRC to reconsider the petitioner's revalidation requests in light of all relevant facts, including decisions concerning similarly situated importers, and to render a reasoned decision. The PRC was instructed to complete the fresh examination expeditiously and preferably within six weeks. The petition was disposed of accordingly.
The HC found prima facie merit in the petitioner's challenge to the respondent's inaction on revalidation of import licences but declined to grant pre-emptory relief or issue a writ of mandamus directing revalidation. Instead, the HC directed the respondent's PRC to reconsider the petitioner's revalidation requests in light of all relevant facts, including decisions concerning similarly situated importers, and to render a reasoned decision. The PRC was instructed to complete the fresh examination expeditiously and preferably within six weeks. The petition was disposed of accordingly.
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TaxTMI 
TaxTMI 
of 4921 
