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...
Valuation - inclusion of TCS collected from the buyer over and above the price of the goods - In the present case the TCS is collected not as a additional consideration but explicitly as tax and same is deposited to the income tax department, therefore, it cannot be said that the amount of TCS belongs to the appellant - the amount of TCS cannot be considered as additional consideration flowing from the buyer to the appellant accordingly, the same is not includable in the assessable value for charging Excise Duty - AT
Valuation - inclusion of TCS collected from the buyer over and above the price of the goods - In the present case the TCS is collected not as a additional consideration but explicitly as tax and same is deposited to the income tax department, therefore, it cannot be said that the amount of TCS belongs to the appellant - the amount of TCS cannot be considered as additional consideration flowing from the buyer to the appellant accordingly, the same is not includable in the assessable value for charging Excise Duty - AT
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