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 before the Commissioner (Appeals) - reassessment of bill of entry - if an assessee wants to challenge the assessment of bill of entry, he should file appeal before the learned Commissioner (Appeals) as the assessment of bill of entry is appealable order therefore, the learned Commissioner (Appeals) should not have rejected the appeal on the ground that the reassessment is not possible, he should have passed the order on merit. - AT
Maintainability of appeal before the Commissioner (Appeals) - reassessment of bill of entry - if an assessee wants to challenge the assessment of bill of entry, he should file appeal before the learned Commissioner (Appeals) as the assessment of bill of entry is appealable order therefore, the learned Commissioner (Appeals) should not have rejected the appeal on the ground that the reassessment is not possible, he should have passed the order on merit. - AT
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