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...
Rebate of Excise Duty - inclusion of post removal charges from the factory gate to the Port of Export - the observations made by the Commissioner (Appeals) clarifying that the circular dated 28.02.2015 is not restricted for availment of CENVAT Credit and would also be applicable on rebate of excise duty is the correct interpretation on facts and law. Thus, the order passed by the Revisionary Authority dated 19.12.2019 does not stand to scrutiny and is hereby reversed and set aside - HC
Rebate of Excise Duty - inclusion of post removal charges from the factory gate to the Port of Export - the observations made by the Commissioner (Appeals) clarifying that the circular dated 28.02.2015 is not restricted for availment of CENVAT Credit and would also be applicable on rebate of excise duty is the correct interpretation on facts and law. Thus, the order passed by the Revisionary Authority dated 19.12.2019 does not stand to scrutiny and is hereby reversed and set aside - HC
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