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...
Penalty under section 271D was time-barred because section 275(1)(c) required the penalty order to be passed within six months from the end of the month in which the penalty notice was issued. The notice was issued in January 2021, making July 2021 the statutory deadline; the March 2022 order fell outside that period. The penalty order was therefore invalid and quashed, and the appellate order was set aside.
Penalty under section 271D was time-barred because section 275(1)(c) required the penalty order to be passed within six months from the end of the month in which the penalty notice was issued. The notice was issued in January 2021, making July 2021 the statutory deadline; the March 2022 order fell outside that period. The penalty order was therefore invalid and quashed, and the appellate order was set aside.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
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