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...
Refund of wrongly paid Central Excise Duty on Retail Sale Price (Maximum Retail Price-MRP) - unjust enrichment - The authorities concluded that the appellant had passed on the incidence of higher duty to their customers. The appellant failed to provide sufficient evidence to prove the non-passing of the duty burden, such as detailed customer ledgers showing accounting of invoices and subsequent credit/debit notes. - The Tribunal found no merit in the appellant's claim for a refund to be paid to them, instead of being credited to the Consumer Welfare Fund.
Refund of wrongly paid Central Excise Duty on Retail Sale Price (Maximum Retail Price-MRP) - unjust enrichment - The authorities concluded that the appellant had passed on the incidence of higher duty to their customers. The appellant failed to provide sufficient evidence to prove the non-passing of the duty burden, such as detailed customer ledgers showing accounting of invoices and subsequent credit/debit notes. - The Tribunal found no merit in the appellant's claim for a refund to be paid to them, instead of being credited to the Consumer Welfare Fund.
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