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...
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Refund of Additional Customs Duty - refund rejected on the ground that the claimant is not the importer of the goods - The agreement is sufficient evidence to satisfy that the ownership of the goods was transferred from Doosan Infracore India Pvt.Ltd. to the appellant herein - before the goods were cleared for home consumption as per slump sale agreement, the liability to pay all duties including SAD on the imported goods is on the appellant. Consequent to slump sale agreement, not only the liability to pay duty but also the right to claim SAD refund also is passed on to the appellant herein - sanction of refund to the appellant is legal and proper. - AT
Refund of Additional Customs Duty - refund rejected on the ground that the claimant is not the importer of the goods - The agreement is sufficient evidence to satisfy that the ownership of the goods was transferred from Doosan Infracore India Pvt.Ltd. to the appellant herein - before the goods were cleared for home consumption as per slump sale agreement, the liability to pay all duties including SAD on the imported goods is on the appellant. Consequent to slump sale agreement, not only the liability to pay duty but also the right to claim SAD refund also is passed on to the appellant herein - sanction of refund to the appellant is legal and proper. - AT
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