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 quashed the impugned order dated 19.10.2022 issued under s.127(1) of the Act. The court found the Revenue's transfer of the petitioner's assessment from Udaipur to Delhi arbitrary, unjustified and contrary to the prior coordinate-bench order which the Revenue had accepted; continued reliance on a transfer for purported uniformity following a s.132(1) search was unreasonable given that assessments in the related group had been completed by December 2019. The HC emphasized that the faceless assessment framework requires transparency and that the Revenue must decide disputes per law rather than treat the assessee as a shuttlecock; consequently the transfer order was declared invalid and set aside.
The HC allowed the writ petition and quashed the impugned order dated 19.10.2022 issued under s.127(1) of the Act. The court found the Revenue's transfer of the petitioner's assessment from Udaipur to Delhi arbitrary, unjustified and contrary to the prior coordinate-bench order which the Revenue had accepted; continued reliance on a transfer for purported uniformity following a s.132(1) search was unreasonable given that assessments in the related group had been completed by December 2019. The HC emphasized that the faceless assessment framework requires transparency and that the Revenue must decide disputes per law rather than treat the assessee as a shuttlecock; consequently the transfer order was declared invalid and set aside.
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