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...
A post-disposal miscellaneous application cannot be used to recall a final non-speaking order dismissing an SLP once the Court has become functus officio; only narrow exceptions such as clerical correction or inability to implement executory directions may justify such relief, so the recall application was dismissed as not maintainable. Alleged suppression, fraud, and later insolvency developments could not be raised collaterally to unsettle final disposal in a different proceeding, though separate remedies before the competent forum remained open. In matters involving withdrawal under Section 12A of the IBC, the choice between settlement options falls within the Committee of Creditors' commercial wisdom, subject only to limited judicial review, so the Court declined to compare competing offers or interfere with that decision.
A post-disposal miscellaneous application cannot be used to recall a final non-speaking order dismissing an SLP once the Court has become functus officio; only narrow exceptions such as clerical correction or inability to implement executory directions may justify such relief, so the recall application was dismissed as not maintainable. Alleged suppression, fraud, and later insolvency developments could not be raised collaterally to unsettle final disposal in a different proceeding, though separate remedies before the competent forum remained open. In matters involving withdrawal under Section 12A of the IBC, the choice between settlement options falls within the Committee of Creditors' commercial wisdom, subject only to limited judicial review, so the Court declined to compare competing offers or interfere with that decision.
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TaxTMI 
TaxTMI 
of 4918 
