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...
Maintainability of petition - alternative remedy of appeal - Validity Of show-cause notice - The petitioner contended that the impugned show-cause notice and order were without jurisdiction because the Additional Commissioner of Customs, who issued them, was not authorized under the SEZ Act notifications of August 5, 2016. - The High Court observed a discrepancy between the petitioner's claim of not receiving notices and the impugned order's assertion that notices were served. This discrepancy led to disputed questions of fact. - As the issue of notice service involved factual disputes, the High Court declined to entertain the petition on this ground, leaving it for the appellate authority to examine during appeal proceedings.
Maintainability of petition - alternative remedy of appeal - Validity Of show-cause notice - The petitioner contended that the impugned show-cause notice and order were without jurisdiction because the Additional Commissioner of Customs, who issued them, was not authorized under the SEZ Act notifications of August 5, 2016. - The High Court observed a discrepancy between the petitioner's claim of not receiving notices and the impugned order's assertion that notices were served. This discrepancy led to disputed questions of fact. - As the issue of notice service involved factual disputes, the High Court declined to entertain the petition on this ground, leaving it for the appellate authority to examine during appeal proceedings.
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TaxTMI 
TaxTMI 
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