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...
Confiscation of imported goods - Black pepper - advance authorisation scheme - diversion of Goods - fulfilment of export obligation or not - The Tribunal found that the appellants indeed imported black pepper without duty payment under the advance authorisation scheme. However, it questioned the validity of the confiscation considering certain procedural irregularities. While acknowledging the 'actual user' condition, the Tribunal found discrepancies in the enforcement of this condition and raised doubts about the appellants' culpability. - The Tribunal upheld the appellants' right to cross-examine witnesses, highlighting the importance of procedural fairness and the need to validate testimonial evidence. - The Tribunal found the imposition of re-export condition exceeding the authority conferred by the statute. - Matter restored back.
Confiscation of imported goods - Black pepper - advance authorisation scheme - diversion of Goods - fulfilment of export obligation or not - The Tribunal found that the appellants indeed imported black pepper without duty payment under the advance authorisation scheme. However, it questioned the validity of the confiscation considering certain procedural irregularities. While acknowledging the 'actual user' condition, the Tribunal found discrepancies in the enforcement of this condition and raised doubts about the appellants' culpability. - The Tribunal upheld the appellants' right to cross-examine witnesses, highlighting the importance of procedural fairness and the need to validate testimonial evidence. - The Tribunal found the imposition of re-export condition exceeding the authority conferred by the statute. - Matter restored back.
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