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...
Section 35G excludes High Court jurisdiction where the question has a direct and proximate relation to the rate of duty, and excisability is part of that assessment; Section 35L therefore provides the proper forum, and the later insertion of Section 35L(2) was held clarificatory and retrospective. On merits, cutting, grooving, routing and fixing aluminium composite panels for site-specific installation did not amount to manufacture because the panels retained their essential identity, character and end use. Marketability is an independent requirement for excisability and must be proved by objective material, but it became irrelevant once no distinct goods emerged. The appeal was allowed and excise duty was held not attracted.
Section 35G excludes High Court jurisdiction where the question has a direct and proximate relation to the rate of duty, and excisability is part of that assessment; Section 35L therefore provides the proper forum, and the later insertion of Section 35L(2) was held clarificatory and retrospective. On merits, cutting, grooving, routing and fixing aluminium composite panels for site-specific installation did not amount to manufacture because the panels retained their essential identity, character and end use. Marketability is an independent requirement for excisability and must be proved by objective material, but it became irrelevant once no distinct goods emerged. The appeal was allowed and excise duty was held not attracted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
