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...
Penalty - The plea that substantial benefit should not be denied for procedural lapse is clearly not tenable as there is fraudulent availment of Cenvat credit without supply of goods and it is not merely a procedural lapse.
Penalty - The plea that substantial benefit should not be denied for procedural lapse is clearly not tenable as there is fraudulent availment of Cenvat credit without supply of goods and it is not merely a procedural lapse.
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