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...
Dividend remittance to foreign shareholders was permitted despite pending tax demands because those demands were already under challenge and stayed, and the Court found that an indefinite embargo on repatriation was unjustified. Revenue protection was maintained by requiring the company to furnish an auto-renewable interest-bearing FDR of equivalent value, comply with remittance rules, and deduct tax at source; the earlier lien on existing FDRs was lifted. Separately, refund for AY 2021-22 was allowed to be adjusted against the demand for AY 2018-19 on the petitioner's concession, and the Department was protected from any contempt allegation if the refund was adjusted against outstanding demand for AY 2020-21.
Dividend remittance to foreign shareholders was permitted despite pending tax demands because those demands were already under challenge and stayed, and the Court found that an indefinite embargo on repatriation was unjustified. Revenue protection was maintained by requiring the company to furnish an auto-renewable interest-bearing FDR of equivalent value, comply with remittance rules, and deduct tax at source; the earlier lien on existing FDRs was lifted. Separately, refund for AY 2021-22 was allowed to be adjusted against the demand for AY 2018-19 on the petitioner's concession, and the Department was protected from any contempt allegation if the refund was adjusted against outstanding demand for AY 2020-21.
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TaxTMI 
TaxTMI 
of 4918 
