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...
Rectification of mistake - error apparent on the face of record - It has been rightly concluded in the final order that though this appellant and others have not made any big gain, in the attempted export of the prohibited goods, by the exporter. However, there has been element of negligence and/or vigilance on their part which has facilitated attempted exported of prohibited goods. - There is no error in the final order - there is no merit in the RoM application, the same is dismissed. - AT
Rectification of mistake - error apparent on the face of record - It has been rightly concluded in the final order that though this appellant and others have not made any big gain, in the attempted export of the prohibited goods, by the exporter. However, there has been element of negligence and/or vigilance on their part which has facilitated attempted exported of prohibited goods. - There is no error in the final order - there is no merit in the RoM application, the same is dismissed. - AT
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