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...
Enhancement of value - old and used worn clothing, completely fumigated - Confiscation - The Tribunal referred to a previous case where it was observed that Section 111(m) should not be invoked if proceedings initiated against imports commenced before the filing of bills of entry. Confiscation under Section 111(d) was deemed appropriate for the import of restricted goods without the necessary import license. Considering various issues and submissions, and the failure to comply with certain directions in a remand, the Tribunal upheld the confiscation but reduced the redemption fine and penalty.
Enhancement of value - old and used worn clothing, completely fumigated - Confiscation - The Tribunal referred to a previous case where it was observed that Section 111(m) should not be invoked if proceedings initiated against imports commenced before the filing of bills of entry. Confiscation under Section 111(d) was deemed appropriate for the import of restricted goods without the necessary import license. Considering various issues and submissions, and the failure to comply with certain directions in a remand, the Tribunal upheld the confiscation but reduced the redemption fine and penalty.
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