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...
Interest on pre-deposit - payment of duty after reversal of duty debited in DEPB scrips is pre-deposit OR duty payment - there cannot be any duty at all when the issue had not yet reached finality and during the pendency of appeal the appellant deposited the entire amount u/s 129E is nothing but pre-deposit of the duty paid - the interest is allwable
Interest on pre-deposit - payment of duty after reversal of duty debited in DEPB scrips is pre-deposit OR duty payment - there cannot be any duty at all when the issue had not yet reached finality and during the pendency of appeal the appellant deposited the entire amount u/s 129E is nothing but pre-deposit of the duty paid - the interest is allwable
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