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...
Levy of Penalty - Jurisdiction - diversion of imported material or not - the assessee has not made any unconditional acceptance of any diversion - the so called letter issued by the assessee cannot be taken to be a case where the assessee accepted the fact that they have not utilized the raw materials for the purpose for which it was imported - the materials which were available cannot be a reason for issuance of the Show Cause Notice - HC
Levy of Penalty - Jurisdiction - diversion of imported material or not - the assessee has not made any unconditional acceptance of any diversion - the so called letter issued by the assessee cannot be taken to be a case where the assessee accepted the fact that they have not utilized the raw materials for the purpose for which it was imported - the materials which were available cannot be a reason for issuance of the Show Cause Notice - HC
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