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...
Finality of tax liability was central to the closure of criminal prosecution. The liability dispute had not become final when the Trial Court closed the prosecution; the tax demand was determined, accepted and complied with only afterwards. Closure on the premise that the liability had already been fully satisfied therefore failed to account for material subsequent developments. The closure order was set aside, and the matter was remanded to the Trial Court for fresh consideration in accordance with law, without any view on the merits of the criminal prosecution.
Finality of tax liability was central to the closure of criminal prosecution. The liability dispute had not become final when the Trial Court closed the prosecution; the tax demand was determined, accepted and complied with only afterwards. Closure on the premise that the liability had already been fully satisfied therefore failed to account for material subsequent developments. The closure order was set aside, and the matter was remanded to the Trial Court for fresh consideration in accordance with law, without any view on the merits of the criminal prosecution.
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TaxTMI 
TaxTMI 
of 4918 
