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...
Delay in filing of appeal before Commissioner (Appeal) - Period of limitation for date of assessment of Bill of entry - to tbe counted from the date of communication of order or from the date of upload on the website - no Court would presume such a document uploaded in the website as genuine unless it is a public document containing seal and signature of the public authority or its certified copy that would meet the requirement of Section 79 of the Indian Evidence Act. - AT
Delay in filing of appeal before Commissioner (Appeal) - Period of limitation for date of assessment of Bill of entry - to tbe counted from the date of communication of order or from the date of upload on the website - no Court would presume such a document uploaded in the website as genuine unless it is a public document containing seal and signature of the public authority or its certified copy that would meet the requirement of Section 79 of the Indian Evidence Act. - AT
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