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...
Excess recovery was alleged where the tax department adjusted refund amounts, including a 10% pre-deposit, towards disputed demand, resulting in collection beyond the 20% ceiling prescribed by administrative instructions. The court held that the taxpayer's representation seeking correction and refund required consideration on merits and directed the authority to decide the representation within six weeks; it further ordered that any amount recovered in excess of 20% of the disputed demand be refunded. - HC
Excess recovery was alleged where the tax department adjusted refund amounts, including a 10% pre-deposit, towards disputed demand, resulting in collection beyond the 20% ceiling prescribed by administrative instructions. The court held that the taxpayer's representation seeking correction and refund required consideration on merits and directed the authority to decide the representation within six weeks; it further ordered that any amount recovered in excess of 20% of the disputed demand be refunded. - HC
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
