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...
Maintainability of appeal - applicability of time limitation - From the discussions made by the Commissioner (Appeals), it is explicit that the department has not been able to furnish any details as to the date of receipt of order by the reviewing authority. - There are no hesitation to conclude that the review order passed by the department is beyond the time-limit prescribed under sub-section (3) of section 129D of the Customs Act, 1962 and therefore the appeals filed before the Commissioner (Appeals) are time-barred. - AT
Maintainability of appeal - applicability of time limitation - From the discussions made by the Commissioner (Appeals), it is explicit that the department has not been able to furnish any details as to the date of receipt of order by the reviewing authority. - There are no hesitation to conclude that the review order passed by the department is beyond the time-limit prescribed under sub-section (3) of section 129D of the Customs Act, 1962 and therefore the appeals filed before the Commissioner (Appeals) are time-barred. - AT
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