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...
Absolute confiscation of gold - The case involved the confiscation of gold by customs authorities from a jeweler, who contested the allegations of smuggling and illegal importation. The appellant provided substantial evidence, including invoices and transaction records, to prove the legality of their gold procurement activities. They argued that the seized gold was domestically sourced and not of foreign origin, highlighting discrepancies in its characteristics. The Appellate Tribunal found merit in the appellant's submissions, criticizing the lower court's reliance on unsubstantiated assumptions. Consequently, the appeal was allowed, and the appellant was granted relief, including the return of seized gold or refund of auction proceeds.
Absolute confiscation of gold - The case involved the confiscation of gold by customs authorities from a jeweler, who contested the allegations of smuggling and illegal importation. The appellant provided substantial evidence, including invoices and transaction records, to prove the legality of their gold procurement activities. They argued that the seized gold was domestically sourced and not of foreign origin, highlighting discrepancies in its characteristics. The Appellate Tribunal found merit in the appellant's submissions, criticizing the lower court's reliance on unsubstantiated assumptions. Consequently, the appeal was allowed, and the appellant was granted relief, including the return of seized gold or refund of auction proceeds.
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TaxTMI 
TaxTMI 
of 4918 
