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...
Excisable goods or not - Superior Kerosene Oil - Even issue of interpretation whether the Superior Kerosene Oil was an excisable product or not and whether the Superior Kerosene Oil falls under Fourth Schedule or not would have bearing on the aspect of eligibility of the Petitioner to file such declaration under the said Scheme or not and thus warrant personal hearing to the Petitioner before deciding the issue of eligibility - the order of rejection is in violation of principal of natural justice and thus, it deserves to be quashed and set aside. - HC
Excisable goods or not - Superior Kerosene Oil - Even issue of interpretation whether the Superior Kerosene Oil was an excisable product or not and whether the Superior Kerosene Oil falls under Fourth Schedule or not would have bearing on the aspect of eligibility of the Petitioner to file such declaration under the said Scheme or not and thus warrant personal hearing to the Petitioner before deciding the issue of eligibility - the order of rejection is in violation of principal of natural justice and thus, it deserves to be quashed and set aside. - HC
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