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 u/s 117 - connivance in overvaluation of goods imported - Employees of the Customs Broker - A perusal of the impugned order does not point out as to what was expected of the present appellant, being one of innumerable employees of the Customs Broker, as his duty to comply with, which the appellant had ‘failed’ to perform. Insofar as this appellant is concerned, the Commissioner himself has observed that there was no direct evidence of connivance. - No penalty - AT
Levy of penalty u/s 117 - connivance in overvaluation of goods imported - Employees of the Customs Broker - A perusal of the impugned order does not point out as to what was expected of the present appellant, being one of innumerable employees of the Customs Broker, as his duty to comply with, which the appellant had ‘failed’ to perform. Insofar as this appellant is concerned, the Commissioner himself has observed that there was no direct evidence of connivance. - No penalty - AT
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