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...
Dominant issue: whether informant is entitled to a final or enhanced reward under the Guidelines for Grant of Rewards to Informants, 2007. Reasoning: Clause 15.1 authorizes an interim reward (Rs.100,000 already paid) and Clauses 2.1, 13.1-13.2 prescribe that a three-member Committee determine final quantum, including adjustments post-appeal; no Committee decision or reasoned order was placed on record. Outcome: respondents must have the prescribed Committee hear the informant and decide-either enhance the reward or confirm no further payment-by a reasoned order within six months. - HC
Dominant issue: whether informant is entitled to a final or enhanced reward under the Guidelines for Grant of Rewards to Informants, 2007. Reasoning: Clause 15.1 authorizes an interim reward (Rs.100,000 already paid) and Clauses 2.1, 13.1-13.2 prescribe that a three-member Committee determine final quantum, including adjustments post-appeal; no Committee decision or reasoned order was placed on record. Outcome: respondents must have the prescribed Committee hear the informant and decide-either enhance the reward or confirm no further payment-by a reasoned order within six months. - HC
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
