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...
HC held that the seizure of Rs. 15.80 lakhs from P1 by the Flying Squad/SST of R5 during Lok Sabha elections and its subsequent handover to the Income Tax Department (R2-R4) was illegal, arbitrary, irrational and without jurisdiction, having been effected in complete disregard of the Election Commission's SOP dated 19.08.2021. HC ruled that the seizure was not pursuant to an Income Tax raid under s.132 IT Act and that the Income Tax authorities wrongly assumed jurisdiction by retaining the amount in the P.D. account. HC directed R2-R4 to release the entire seized cash to P1 within four weeks, failing which R2-R4 shall pay interest at 9% p.a. from 05.04.2024 until actual refund. The writ petition was allowed.
HC held that the seizure of Rs. 15.80 lakhs from P1 by the Flying Squad/SST of R5 during Lok Sabha elections and its subsequent handover to the Income Tax Department (R2-R4) was illegal, arbitrary, irrational and without jurisdiction, having been effected in complete disregard of the Election Commission's SOP dated 19.08.2021. HC ruled that the seizure was not pursuant to an Income Tax raid under s.132 IT Act and that the Income Tax authorities wrongly assumed jurisdiction by retaining the amount in the P.D. account. HC directed R2-R4 to release the entire seized cash to P1 within four weeks, failing which R2-R4 shall pay interest at 9% p.a. from 05.04.2024 until actual refund. The writ petition was allowed.
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