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...
Extended period of limitation - demand of service tax with penalty - The provisions of section 73(4) of the Finance Act are not applicable because intention of the appellant is not established - penalty under section 78 of the Finance Act is set aside as suppression is not proved - penalty under sections 77(1) and 77(2) of the Finance Act are set aside by invoking the provision of section 80 of the Finance Act - AT
Extended period of limitation - demand of service tax with penalty - The provisions of section 73(4) of the Finance Act are not applicable because intention of the appellant is not established - penalty under section 78 of the Finance Act is set aside as suppression is not proved - penalty under sections 77(1) and 77(2) of the Finance Act are set aside by invoking the provision of section 80 of the Finance Act - AT
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