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...
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Fair-hearing requirements require supply of documents relied on in pleadings where the retention order is founded on them; service of a panchnama alone does not provide an adequate opportunity to respond. Retention of seized documents is justified only when they are relied on in a prosecution complaint or supplementary complaint and required to prove the case against an accused. Documents not so required must be released within a reasonable time, while authenticated photocopies may be retained. The retention direction was consequently limited to documents necessary as prosecution evidence.
Fair-hearing requirements require supply of documents relied on in pleadings where the retention order is founded on them; service of a panchnama alone does not provide an adequate opportunity to respond. Retention of seized documents is justified only when they are relied on in a prosecution complaint or supplementary complaint and required to prove the case against an accused. Documents not so required must be released within a reasonable time, while authenticated photocopies may be retained. The retention direction was consequently limited to documents necessary as prosecution evidence.
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