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 dominant issue was whether the Assessing Officer could pass an order giving effect to DRP directions after expiry of the one-month period mandated by section 144C(13). The court held that section 144C(13) imposes a strict, mandatory timeline, and statutory requirements must be complied with in the prescribed manner; treating the time limit as directory would negate the provision's mandatory character. Since the one-month period had already lapsed, the pending proceedings to give effect to the DRP directions, including the transfer pricing addition, were barred by limitation and could not be continued under section 144C(13). - HC
The dominant issue was whether the Assessing Officer could pass an order giving effect to DRP directions after expiry of the one-month period mandated by section 144C(13). The court held that section 144C(13) imposes a strict, mandatory timeline, and statutory requirements must be complied with in the prescribed manner; treating the time limit as directory would negate the provision's mandatory character. Since the one-month period had already lapsed, the pending proceedings to give effect to the DRP directions, including the transfer pricing addition, were barred by limitation and could not be continued under section 144C(13). - HC
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TaxTMI 
TaxTMI 
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