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...
Condonation of inordinate delay requires a pleaded and substantiated sufficient cause; filing before a court without territorial jurisdiction and subsequent administrative movement of papers, without a pleaded pandemic-related impediment, do not establish it. Gross negligence, deliberate inaction and unexplained delay undermine finality and certainty under limitation law, while delay may prejudice the opposing side. On these principles, the revenue's condonation request was rejected and its appeal was treated as barred by limitation.
Condonation of inordinate delay requires a pleaded and substantiated sufficient cause; filing before a court without territorial jurisdiction and subsequent administrative movement of papers, without a pleaded pandemic-related impediment, do not establish it. Gross negligence, deliberate inaction and unexplained delay undermine finality and certainty under limitation law, while delay may prejudice the opposing side. On these principles, the revenue's condonation request was rejected and its appeal was treated as barred by limitation.
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TaxTMI 
TaxTMI 
of 4918 
