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...
Indefinite adjournment of a reserved appeal was held unjustified where a related appeal had been admitted but no stay of the admitted matter's operation existed; the tribunal, having reserved its order, could not simply post the case sine die without protecting the assessee's interests. The court found such post-reservation adjournment prejudicial, wasteful of resources and aggravating of grievance, set aside the indefinite postponement, declined to decide merits, and directed the tribunal to determine the appeal in accordance with law within a specified short period.
Indefinite adjournment of a reserved appeal was held unjustified where a related appeal had been admitted but no stay of the admitted matter's operation existed; the tribunal, having reserved its order, could not simply post the case sine die without protecting the assessee's interests. The court found such post-reservation adjournment prejudicial, wasteful of resources and aggravating of grievance, set aside the indefinite postponement, declined to decide merits, and directed the tribunal to determine the appeal in accordance with law within a specified short period.
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