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...
Imposition of penalty u/s 112 (d) and 114AA of the Customs Act, 1962 on Customs Broker - appellant was only a Customs Broker and not the importer - the only allegation levelled against the appellant is that the appellant did not inform the Revenue that the importer did not possess licence for import of R-22 gas - Revenue has not been able to establish the mala fides - No penalty.
Imposition of penalty u/s 112 (d) and 114AA of the Customs Act, 1962 on Customs Broker - appellant was only a Customs Broker and not the importer - the only allegation levelled against the appellant is that the appellant did not inform the Revenue that the importer did not possess licence for import of R-22 gas - Revenue has not been able to establish the mala fides - No penalty.
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