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...
Bid-rigging was proved by direct and circumstantial email evidence showing coordinated bidding, allocation of shares, tender distribution, price discussions, bid withdrawal directions and continued receipt of cartel communications without dissociation; contravention under Sections 3(1) and 3(3)(a) to (d) was therefore affirmed. Once cartel conduct was established, the presumption of appreciable adverse effect on competition applied and was not rebutted; reliance on Rajasthan Cylinder was distinguished. The partner's liability under Section 48 was upheld, and penalty based on average income at the same rate as the firm was held proper. Challenges based on vacancy in composition and denial of cross-examination failed, and both appeals were dismissed.
Bid-rigging was proved by direct and circumstantial email evidence showing coordinated bidding, allocation of shares, tender distribution, price discussions, bid withdrawal directions and continued receipt of cartel communications without dissociation; contravention under Sections 3(1) and 3(3)(a) to (d) was therefore affirmed. Once cartel conduct was established, the presumption of appreciable adverse effect on competition applied and was not rebutted; reliance on Rajasthan Cylinder was distinguished. The partner's liability under Section 48 was upheld, and penalty based on average income at the same rate as the firm was held proper. Challenges based on vacancy in composition and denial of cross-examination failed, and both appeals were dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4921 
