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...
Disallowance of Cenvat credit as was distributed by the appellant’s Input Service Credit Distributor (ISD) - input services or not - extended period of limitation - The adjudicating authority below has failed to appreciate the catena of decisions not only of this Tribunal but also of their own department with respect to the impugned services and even with the decisions passed by departmental authorities in favour of the present appellant themselves permitting them to avail Cenvat credit distributed by their ISD. The order under challenge is therefore hereby set aside. - AT
Disallowance of Cenvat credit as was distributed by the appellant’s Input Service Credit Distributor (ISD) - input services or not - extended period of limitation - The adjudicating authority below has failed to appreciate the catena of decisions not only of this Tribunal but also of their own department with respect to the impugned services and even with the decisions passed by departmental authorities in favour of the present appellant themselves permitting them to avail Cenvat credit distributed by their ISD. The order under challenge is therefore hereby set aside. - AT
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