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...
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Statutory pre-deposit under the erstwhile indirect tax regime is a security furnished as a condition for hearing an appeal, rather than duty. Where first appellate relief sets aside part of a demand and the Department does not challenge that relief, the appellate order becomes final to that extent. Refund of the corresponding pre-deposit cannot be refused merely because the taxpayer intends to challenge the remaining sustained demand. The refund claim attributable to the demand set aside was required to be processed and paid, while no interest claim was pursued.
Statutory pre-deposit under the erstwhile indirect tax regime is a security furnished as a condition for hearing an appeal, rather than duty. Where first appellate relief sets aside part of a demand and the Department does not challenge that relief, the appellate order becomes final to that extent. Refund of the corresponding pre-deposit cannot be refused merely because the taxpayer intends to challenge the remaining sustained demand. The refund claim attributable to the demand set aside was required to be processed and paid, while no interest claim was pursued.
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