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...
100% EOU - Conversion of free shipping bills filed under EOU scheme into drawback shipping bills - In the present case, the request is only for conversion of free shipping bills in terms of section 149 of the Customs Act, 1962. It is not the case of the department that the appellant has not produced sufficient document to prove that the export of goods were done by them. So also there is no allegation that there is delay in filing the request for conversion. On such score, the request for conversion cannot be denied - AT
100% EOU - Conversion of free shipping bills filed under EOU scheme into drawback shipping bills - In the present case, the request is only for conversion of free shipping bills in terms of section 149 of the Customs Act, 1962. It is not the case of the department that the appellant has not produced sufficient document to prove that the export of goods were done by them. So also there is no allegation that there is delay in filing the request for conversion. On such score, the request for conversion cannot be denied - AT
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