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...
Reassessment of Bill of Entry - case of the Revenue is that respondent should have appealed before the Commissioner (Appeals) against the assessment of the Bill of Entry whereas they have filed appeal against the rejection of reassessment made by the assessing authority - now the Revenue cannot challenge the direction of reassessment given by the Ld. Commissioner. Therefore, on this score Revenue appeal does not sustain. - AT
Reassessment of Bill of Entry - case of the Revenue is that respondent should have appealed before the Commissioner (Appeals) against the assessment of the Bill of Entry whereas they have filed appeal against the rejection of reassessment made by the assessing authority - now the Revenue cannot challenge the direction of reassessment given by the Ld. Commissioner. Therefore, on this score Revenue appeal does not sustain. - AT
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