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...
Under the Indo-Thai Free Trade Agreement, Indian customs authorities could not disregard Certificates of Origin once the Thai authorities had confirmed their authenticity and issuance by the Department of Foreign Trade, Thailand. The decision treats that foreign certification as conclusive for concessional duty purposes and bars an independent Indian enquiry that would undermine the Interim Rules of Origin. A statement recorded from the importer under the Customs Act could not affect the authenticity of the certificates. The Tribunal's view was upheld, and the Revenue's challenge failed because no substantial question of law arose.
Under the Indo-Thai Free Trade Agreement, Indian customs authorities could not disregard Certificates of Origin once the Thai authorities had confirmed their authenticity and issuance by the Department of Foreign Trade, Thailand. The decision treats that foreign certification as conclusive for concessional duty purposes and bars an independent Indian enquiry that would undermine the Interim Rules of Origin. A statement recorded from the importer under the Customs Act could not affect the authenticity of the certificates. The Tribunal's view was upheld, and the Revenue's challenge failed because no substantial question of law arose.
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TaxTMI 
TaxTMI 
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