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...
A statutory appeal cannot be disposed of for default of appearance alone and must be decided on merits; applying that principle, the Tribunal considered the matter on the available record. It also held that personal penalties imposed on persons connected with an importer were purely consequential to the demand and confiscation against the importer. Because the importer's own appeal had already been remanded and the confirmation of demand and confiscation no longer survived, the penalties had no remaining legal foundation and were set aside.
A statutory appeal cannot be disposed of for default of appearance alone and must be decided on merits; applying that principle, the Tribunal considered the matter on the available record. It also held that personal penalties imposed on persons connected with an importer were purely consequential to the demand and confiscation against the importer. Because the importer's own appeal had already been remanded and the confirmation of demand and confiscation no longer survived, the penalties had no remaining legal foundation and were set aside.
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TaxTMI 
TaxTMI 
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