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...
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Valuation of imported Goods - Allowance of discount of 25% to appellant by foreign supplier - related party transaction - remittances made higher than the invoice price or not - The Tribunal criticized the department for disregarding crucial evidence, such as email communications and an amended agreement explicitly stating the 25% discount. The Tribunal found the department's dismissal of the email as an afterthought unjustified, especially considering the continuous litigation and the subsequent production of the amended agreement. Ultimately, the Tribunal ruled in favor of the appellant, acknowledging the validity of the 25% discount.
Valuation of imported Goods - Allowance of discount of 25% to appellant by foreign supplier - related party transaction - remittances made higher than the invoice price or not - The Tribunal criticized the department for disregarding crucial evidence, such as email communications and an amended agreement explicitly stating the 25% discount. The Tribunal found the department's dismissal of the email as an afterthought unjustified, especially considering the continuous litigation and the subsequent production of the amended agreement. Ultimately, the Tribunal ruled in favor of the appellant, acknowledging the validity of the 25% discount.
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