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...
Customs duty cannot be fastened jointly and severally on multiple noticees without first determining the actual importer and the role of each person. The Tribunal held that the adjudicating authority must examine the documentary evidence, record clear factual findings on individual responsibility, and then fix duty and penalty, if warranted, on the person concerned. Because the impugned order had imposed liability without that determination, it was set aside against the appellants and the matter was remanded for de novo adjudication by a speaking order, with all contentions left open.
Customs duty cannot be fastened jointly and severally on multiple noticees without first determining the actual importer and the role of each person. The Tribunal held that the adjudicating authority must examine the documentary evidence, record clear factual findings on individual responsibility, and then fix duty and penalty, if warranted, on the person concerned. Because the impugned order had imposed liability without that determination, it was set aside against the appellants and the matter was remanded for de novo adjudication by a speaking order, with all contentions left open.
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TaxTMI 
TaxTMI 
of 4918 
