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...
Refund of SAD - Appeal found to be filed beyond the period of one year from the relevant date - Substantial quantity of imported goods was sold by the appellant in the year 2016 itself - There is no sufficient reason quoted for waiting till March, 2018. In the absence of such explanation it is held that limitation mentioned in the amended N/N. 102/2007 is rightly invokable for the impugned refund claim. - AT
Refund of SAD - Appeal found to be filed beyond the period of one year from the relevant date - Substantial quantity of imported goods was sold by the appellant in the year 2016 itself - There is no sufficient reason quoted for waiting till March, 2018. In the absence of such explanation it is held that limitation mentioned in the amended N/N. 102/2007 is rightly invokable for the impugned refund claim. - AT
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TaxTMI 
TaxTMI 
of 4918 
