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...
The HC held that the demand in DRC-07 dated 31.12.2023, seeking recovery of tax already discharged, was prima facie unsustainable because Revenue's SCN/DRC-01 dated 12.04.2023 addressed only interest. Consequently, the attachment of the petitioner's bank account with the second respondent bank was declared unsustainable and must be lifted. The HC directed the first respondent to effect recovery solely of the interest component confirmed by the order dated 31.12.2023 directly from the petitioner's account and to raise the order of attachment forthwith to reflect that limited recovery. The petition was accordingly disposed of.
The HC held that the demand in DRC-07 dated 31.12.2023, seeking recovery of tax already discharged, was prima facie unsustainable because Revenue's SCN/DRC-01 dated 12.04.2023 addressed only interest. Consequently, the attachment of the petitioner's bank account with the second respondent bank was declared unsustainable and must be lifted. The HC directed the first respondent to effect recovery solely of the interest component confirmed by the order dated 31.12.2023 directly from the petitioner's account and to raise the order of attachment forthwith to reflect that limited recovery. The petition was accordingly disposed of.
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