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...
Process amounting to manufacture or not - repacking - The goods are sold at the same MRP to the consumer. It is nobody’s case that the goods are sold above the MRP to the consumer. The goods received by the vendor are already in a prepacked form and bears necessary declaration including MRP as prescribed under the statutory provisions and they have already been subjected to Excise Duty earlier. - HC
Process amounting to manufacture or not - repacking - The goods are sold at the same MRP to the consumer. It is nobody’s case that the goods are sold above the MRP to the consumer. The goods received by the vendor are already in a prepacked form and bears necessary declaration including MRP as prescribed under the statutory provisions and they have already been subjected to Excise Duty earlier. - HC
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