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...
FTWZ operations were not treated as having been undertaken under the customs broker licence because there was no Form C intimation extending the licence to SEZ/FTWZ activity and no evidence that the licence covered business in the SEZ unit. The inquiry report was treated as the ative document in the CBLR proceedings; once it recorded that the alleged violations of Regulation 10(d), (e) and (n) were not proved, revocation of licence, forfeiture of security and penalty could not be sustained. The order dropping the proceedings was upheld and the Revenue appeal was dismissed.
FTWZ operations were not treated as having been undertaken under the customs broker licence because there was no Form C intimation extending the licence to SEZ/FTWZ activity and no evidence that the licence covered business in the SEZ unit. The inquiry report was treated as the ative document in the CBLR proceedings; once it recorded that the alleged violations of Regulation 10(d), (e) and (n) were not proved, revocation of licence, forfeiture of security and penalty could not be sustained. The order dropping the proceedings was upheld and the Revenue appeal was dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
