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...
Written acknowledgment of a subsisting debt before expiry of limitation can extend time under Section 18 of the Limitation Act, and such acknowledgment by the principal borrower may bind a personal guarantor because of co-extensive liability. A communication marked "without prejudice" does not lose evidentiary value if, read as a whole, it clearly records repayment, restructuring, or continuation of settlement discussions and amounts to an unequivocal admission of liability. An irrevocable and unconditional personal guarantee cannot be unilaterally revoked by later notice, and a release plea fails where the alleged release document is not properly brought on record.
Written acknowledgment of a subsisting debt before expiry of limitation can extend time under Section 18 of the Limitation Act, and such acknowledgment by the principal borrower may bind a personal guarantor because of co-extensive liability. A communication marked "without prejudice" does not lose evidentiary value if, read as a whole, it clearly records repayment, restructuring, or continuation of settlement discussions and amounts to an unequivocal admission of liability. An irrevocable and unconditional personal guarantee cannot be unilaterally revoked by later notice, and a release plea fails where the alleged release document is not properly brought on record.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4921 
