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 dismissed the writ petition challenging rejection of condonation of delay in filing ITR for AY 2018-19. It held that a 30-month delay could not be excused under the "genuine hardship" proviso merely on the generic plea of disputes between directors and financial difficulty, particularly when the company remained a going concern and had duly filed ITRs for AYs 2017-18 and 2019-20. The Court found no documentary proof of the alleged director dispute and concluded that statutory obligations cannot be deferred on such assertions. Relying on precedent, the HC held that liberal construction of "genuine hardship" cannot extend to condoning such inordinate, unjustified delay.
HC dismissed the writ petition challenging rejection of condonation of delay in filing ITR for AY 2018-19. It held that a 30-month delay could not be excused under the "genuine hardship" proviso merely on the generic plea of disputes between directors and financial difficulty, particularly when the company remained a going concern and had duly filed ITRs for AYs 2017-18 and 2019-20. The Court found no documentary proof of the alleged director dispute and concluded that statutory obligations cannot be deferred on such assertions. Relying on precedent, the HC held that liberal construction of "genuine hardship" cannot extend to condoning such inordinate, unjustified delay.
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