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...
Where liability was sought to be fastened on a power-of-attorney holder for dues attributed to a deceased proprietor, and service of notice as well as the basis of personal liability were disputed, the Court declined to examine the merits in writ jurisdiction. It held that the petitioner should first pursue the statutory remedy before the Certificate Officer under Section 9 of the Bengal Public Demand Recovery Act, 1913, and directed that the objection be decided on merits without rejection merely on delay. Limited interim protection was granted by staying any unexecuted warrant of arrest to enable recourse to that remedy.
Where liability was sought to be fastened on a power-of-attorney holder for dues attributed to a deceased proprietor, and service of notice as well as the basis of personal liability were disputed, the Court declined to examine the merits in writ jurisdiction. It held that the petitioner should first pursue the statutory remedy before the Certificate Officer under Section 9 of the Bengal Public Demand Recovery Act, 1913, and directed that the objection be decided on merits without rejection merely on delay. Limited interim protection was granted by staying any unexecuted warrant of arrest to enable recourse to that remedy.
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