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...
Clandestine Removal - Confectionery Items - this manufacturer was availing SSI exemption benefit due to which there was no necessity to prepare the statutory records. The department had put no effort to examine the computerized records. There is no evidence even about any cash flow which may prove the element of any mens rea / bad intention to evade the duty, question of imposition of penalty does not at all arise. - AT
Clandestine Removal - Confectionery Items - this manufacturer was availing SSI exemption benefit due to which there was no necessity to prepare the statutory records. The department had put no effort to examine the computerized records. There is no evidence even about any cash flow which may prove the element of any mens rea / bad intention to evade the duty, question of imposition of penalty does not at all arise. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
