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 u/s 112 and 114AA of the Customs Act, 1962 - Executives / Employees of freight and forwarding agent - existence of mensrea - deliberate connivance with the main noticees in changing the name of the consignee - There is nothing on record to impute knowledge about the usage of false or incorrect material in the transactions undertaken as regards the present two appellants - In fact, the show cause notice does not remotely alleges and castigates the two appellants herein for manipulation and forgery in the bill of lading. - No penalty - AT
Levy of penalty u/s 112 and 114AA of the Customs Act, 1962 - Executives / Employees of freight and forwarding agent - existence of mensrea - deliberate connivance with the main noticees in changing the name of the consignee - There is nothing on record to impute knowledge about the usage of false or incorrect material in the transactions undertaken as regards the present two appellants - In fact, the show cause notice does not remotely alleges and castigates the two appellants herein for manipulation and forgery in the bill of lading. - No penalty - AT
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