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...
Levy of penalty on steamer agent - Undeclared consignment - iolation of conditions / instructions contained in the Board Circular - Revenue has not whispered anywhere if it was the duty of the Steamer Agent to seek clearance of any goods since it is the importer who is required to fulfil any obligations ‘at the time of clearance of goods’ - The penalty under Section 112(a) of the Customs Act, 1962, as levied and confirmed on the appellant, is not sustainable - AT
Levy of penalty on steamer agent - Undeclared consignment - iolation of conditions / instructions contained in the Board Circular - Revenue has not whispered anywhere if it was the duty of the Steamer Agent to seek clearance of any goods since it is the importer who is required to fulfil any obligations ‘at the time of clearance of goods’ - The penalty under Section 112(a) of the Customs Act, 1962, as levied and confirmed on the appellant, is not sustainable - AT
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