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...
Quantum of penalty levied under Section 114 (iii) of the Customs Act, 1962 - fraudulent export as goods were grossly undervalued - the appellant has acted only on the instruction of the employer and more so on the basis of the signed documents i.e. invoice given by his employer. - The exorbitant penalty of ₹ 75 Lacs is not justified - the penalty is reduced from ₹ 75 Lacs to ₹ 25,000/-. - AT
Quantum of penalty levied under Section 114 (iii) of the Customs Act, 1962 - fraudulent export as goods were grossly undervalued - the appellant has acted only on the instruction of the employer and more so on the basis of the signed documents i.e. invoice given by his employer. - The exorbitant penalty of ₹ 75 Lacs is not justified - the penalty is reduced from ₹ 75 Lacs to ₹ 25,000/-. - AT
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