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...
A 13-day delay in filing Form 10-IC for the concessional regime under section 115BAA was condoned because the delay was short, arose from undisputed circumstances linked to the death of the group founder/chairman, and was neither deliberate nor mala fide. The Court treated the benefit under section 115BAA as a substantive statutory entitlement and Form 10-IC as only the procedural mode for exercising that option; a procedural lapse could not defeat eligibility where no dispute existed on the substantive conditions. The refusal to condone was quashed for undue technicality, absence of prejudice to the Revenue, and failure to account for disproportionate hardship.
A 13-day delay in filing Form 10-IC for the concessional regime under section 115BAA was condoned because the delay was short, arose from undisputed circumstances linked to the death of the group founder/chairman, and was neither deliberate nor mala fide. The Court treated the benefit under section 115BAA as a substantive statutory entitlement and Form 10-IC as only the procedural mode for exercising that option; a procedural lapse could not defeat eligibility where no dispute existed on the substantive conditions. The refusal to condone was quashed for undue technicality, absence of prejudice to the Revenue, and failure to account for disproportionate hardship.
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