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...
Smuggling - Absolute Confiscation - The Appellate Tribunal found that the Customs department failed to prove that the mosquito repellents and ladies garments were smuggled items. The department did not provide sufficient evidence to establish the smuggled nature of these goods. Additionally, these items were not listed as prohibited items under Section 123 of the Customs Act, 1962. Therefore, the Tribunal ruled that these goods cannot be confiscated. - Regarding the green-colored refrigerant gas cylinders containing HCFC gas, the Tribunal acknowledged that these were restricted items but not prohibited items. Merely stating that the goods could only be manufactured in China was deemed insufficient to justify their confiscation. Hence, the Tribunal held that the HCFC gas cannot be confiscated.
Smuggling - Absolute Confiscation - The Appellate Tribunal found that the Customs department failed to prove that the mosquito repellents and ladies garments were smuggled items. The department did not provide sufficient evidence to establish the smuggled nature of these goods. Additionally, these items were not listed as prohibited items under Section 123 of the Customs Act, 1962. Therefore, the Tribunal ruled that these goods cannot be confiscated. - Regarding the green-colored refrigerant gas cylinders containing HCFC gas, the Tribunal acknowledged that these were restricted items but not prohibited items. Merely stating that the goods could only be manufactured in China was deemed insufficient to justify their confiscation. Hence, the Tribunal held that the HCFC gas cannot be confiscated.
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