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...
Delay in filing Form 10 was condoned where refusal would have exposed the assessee to tax liability and caused grave hardship despite no benefit arising from the delay. The High Court accepted the explanation that the default resulted from the Chartered Accountant's failure, supported by affidavit, and noted that the same officer had already condoned the delay in filing the return of income. On these facts, the rejection of condonation was unsustainable. The impugned order was quashed, the delay in Form 10 was condoned, and the return was directed to be processed in accordance with law.
Delay in filing Form 10 was condoned where refusal would have exposed the assessee to tax liability and caused grave hardship despite no benefit arising from the delay. The High Court accepted the explanation that the default resulted from the Chartered Accountant's failure, supported by affidavit, and noted that the same officer had already condoned the delay in filing the return of income. On these facts, the rejection of condonation was unsustainable. The impugned order was quashed, the delay in Form 10 was condoned, and the return was directed to be processed in accordance with law.
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