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...
Area based exemption - when both JMAPL and SE could have availed the full duty exemption under notification no. 50/03-CE - they did not file the declaration for availing of this exemption under belief that there activity does not amount to manufacture, no malafide can be attributed to them. - demand set aside as extended period of limitation not applicable - AT
Area based exemption - when both JMAPL and SE could have availed the full duty exemption under notification no. 50/03-CE - they did not file the declaration for availing of this exemption under belief that there activity does not amount to manufacture, no malafide can be attributed to them. - demand set aside as extended period of limitation not applicable - AT
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