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...
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Presumption of service by post governed the appeal, with proof of delivery under the General Clauses Act treated as prima facie evidence; the burden rested on the assessee to rebut non-receipt. The tribunal applied the doctrine that one cannot take advantage of ones own mistake (commodum ex injuria sua nemo habere debet) in light of unchanged registered principal place of business and misleading affidavits, concluding evidentiary presumption stood unrebutted. The consequence was acceptance of service at the registered address and dismissal of the appeal.
Presumption of service by post governed the appeal, with proof of delivery under the General Clauses Act treated as prima facie evidence; the burden rested on the assessee to rebut non-receipt. The tribunal applied the doctrine that one cannot take advantage of ones own mistake (commodum ex injuria sua nemo habere debet) in light of unchanged registered principal place of business and misleading affidavits, concluding evidentiary presumption stood unrebutted. The consequence was acceptance of service at the registered address and dismissal of the appeal.
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