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...
100% EOU - Refund of unutilized CENVAT Credit - The refund claim of the appellant is not a claim u/s 11 B per se and therefore provisions of 11 B cannot be blindly applied in this case because, there is no disputes that the refund claim was under Rule 5 and the allowability or otherwise could only be as per the guidelines or the proviso under Rule 5 ibid
100% EOU - Refund of unutilized CENVAT Credit - The refund claim of the appellant is not a claim u/s 11 B per se and therefore provisions of 11 B cannot be blindly applied in this case because, there is no disputes that the refund claim was under Rule 5 and the allowability or otherwise could only be as per the guidelines or the proviso under Rule 5 ibid
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