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...
Absolute confiscation of imported computer hard discs was set aside because the goods had already been redeemed on payment of fine and were unavailable for further redemption; the confiscation merits had attained finality. Reliance on Supreme Court precedent supporting redemption meant that a subsequent absolute-confiscation direction was non-est in law. Enhanced penalties on the importer and its business head were also set aside because the original penalties were proportionate to the offence and market value had not been determined to establish the profit margin. The adjudication order allowing redemption and imposing the original penalties was sustained.
Absolute confiscation of imported computer hard discs was set aside because the goods had already been redeemed on payment of fine and were unavailable for further redemption; the confiscation merits had attained finality. Reliance on Supreme Court precedent supporting redemption meant that a subsequent absolute-confiscation direction was non-est in law. Enhanced penalties on the importer and its business head were also set aside because the original penalties were proportionate to the offence and market value had not been determined to establish the profit margin. The adjudication order allowing redemption and imposing the original penalties was sustained.
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