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...
Enhancement of the value of the imported goods twice - When the freight is pre-paid and inclusive in the price, there is no requirement to add element of freight @20% for USD 585. - It is also observed that about the invoice produced by the shipping line, the appellant had no knowledge and it is not also known when such invoice was produced before custom authority at the port of export - enhancement of the value from USD 531 to UD 585 is without any basis and the same is not sustainable. - AT
Enhancement of the value of the imported goods twice - When the freight is pre-paid and inclusive in the price, there is no requirement to add element of freight @20% for USD 585. - It is also observed that about the invoice produced by the shipping line, the appellant had no knowledge and it is not also known when such invoice was produced before custom authority at the port of export - enhancement of the value from USD 531 to UD 585 is without any basis and the same is not sustainable. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
