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...
Post-export amendment of shipping bills to change the scheme code from drawback to RoSCTL was treated as permissible under Section 149, because the three-month limit in Circular No. 36/2010 was not supported by valid law. The text notes that time limits for such amendments could be prescribed only through regulations under Section 157, and that later 2025 regulations reinforced that position. On that basis, the adjudicating authority's decision allowing the amendment was upheld and the Revenue's challenge was rejected.
Post-export amendment of shipping bills to change the scheme code from drawback to RoSCTL was treated as permissible under Section 149, because the three-month limit in Circular No. 36/2010 was not supported by valid law. The text notes that time limits for such amendments could be prescribed only through regulations under Section 157, and that later 2025 regulations reinforced that position. On that basis, the adjudicating authority's decision allowing the amendment was upheld and the Revenue's challenge was rejected.
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