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...
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Levy of penalty on CHA - allegation of abetting some unscrupulous exporters - mens rea - The CHA are merely but processing agent on documents of clearance of goods through Customs House. They are not the Inspector to inspect the genuineness of transactions nor they have any allegation to look into the information receive from the exporter/importer. - it is clear that there is no such evidence on record which may prove knowledge with the appellants about the alleged mis-declaration. In such circumstances, the order imposing penalties upon the appellants is now sustainable - AT
Levy of penalty on CHA - allegation of abetting some unscrupulous exporters - mens rea - The CHA are merely but processing agent on documents of clearance of goods through Customs House. They are not the Inspector to inspect the genuineness of transactions nor they have any allegation to look into the information receive from the exporter/importer. - it is clear that there is no such evidence on record which may prove knowledge with the appellants about the alleged mis-declaration. In such circumstances, the order imposing penalties upon the appellants is now sustainable - AT
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