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...
Preferential customs-duty exemption under the Indo-Thailand Free Trade Agreement depends on compliance with the prescribed process for verifying a Certificate of Origin under the Interim Rules of Origin. The text states that Revenue did not follow the procedure in Notification No. 101/2004-Cus. (N.T.) before challenging the certificate's credibility. It therefore records that denial of exemption under Notification No. 85/2004-Cus. was unsustainable, as was the consequential penalty for alleged improper import. The impugned order was set aside and the appeals were allowed with consequential relief.
Preferential customs-duty exemption under the Indo-Thailand Free Trade Agreement depends on compliance with the prescribed process for verifying a Certificate of Origin under the Interim Rules of Origin. The text states that Revenue did not follow the procedure in Notification No. 101/2004-Cus. (N.T.) before challenging the certificate's credibility. It therefore records that denial of exemption under Notification No. 85/2004-Cus. was unsustainable, as was the consequential penalty for alleged improper import. The impugned order was set aside and the appeals were allowed with consequential relief.
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