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...
The text addresses personal liability of directors in regulatory enforcement, holding that designation alone does not establish personal liability and that vicarious liability requires specific findings of individual involvement; this principle limits attachment of personal bank, demat and trading accounts absent substantive averments. It emphasises principles of natural justice and the limited scope of judicial review under Article 226 where regulatory findings entail factual appreciation, concluding that reasoned statutory orders invoking recovery and attachment powers under the SEBI Act warrant pursuit of the alternative statutory remedy before the Securities Appellate Tribunal rather than writ relief.
The text addresses personal liability of directors in regulatory enforcement, holding that designation alone does not establish personal liability and that vicarious liability requires specific findings of individual involvement; this principle limits attachment of personal bank, demat and trading accounts absent substantive averments. It emphasises principles of natural justice and the limited scope of judicial review under Article 226 where regulatory findings entail factual appreciation, concluding that reasoned statutory orders invoking recovery and attachment powers under the SEBI Act warrant pursuit of the alternative statutory remedy before the Securities Appellate Tribunal rather than writ relief.
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TaxTMI 
TaxTMI 
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