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...
Rejection of amendment/ conversion of Shipping Bills - non-submission of necessary documents - It does not lie in the mouth of the appellant to contend that though the Tribunal had directed the appellant to submit documents before the Commissioner to prove its claim, the Commissioner should on his own have called for the documents from his office even if the appellant had failed to produce the documents. - AT
Rejection of amendment/ conversion of Shipping Bills - non-submission of necessary documents - It does not lie in the mouth of the appellant to contend that though the Tribunal had directed the appellant to submit documents before the Commissioner to prove its claim, the Commissioner should on his own have called for the documents from his office even if the appellant had failed to produce the documents. - AT
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