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...
Imposition of penalty under Rule 26 (2) of CER - availment of irregular CENVAT Credit - invoices without actual receipt of inputs - Though the opting of SVLDRS should not have any bearing on the other cases who are contesting before this Tribunal but it shows that the other party to whom Invoices were supplied has accepted the demand of fraudulent Cenvat Credit. - The appellant is liable for penalty under Rule 26 (2) for wrongly passing of the credit - AT
Imposition of penalty under Rule 26 (2) of CER - availment of irregular CENVAT Credit - invoices without actual receipt of inputs - Though the opting of SVLDRS should not have any bearing on the other cases who are contesting before this Tribunal but it shows that the other party to whom Invoices were supplied has accepted the demand of fraudulent Cenvat Credit. - The appellant is liable for penalty under Rule 26 (2) for wrongly passing of the credit - AT
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