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 of betel nut and black pepper of foreign origin - The Appellate Tribunal observed that while the ARDF report suggested the goods might be of Indonesian origin, it was not conclusively proven. As there was no definitive evidence establishing the goods as smuggled or foreign in origin beyond the ARDF report, the Tribunal held that the Revenue failed to discharge the onus to prove the goods' nature. Consequently, the Tribunal set aside the penalties imposed on the appellants, ruling in their favor.
Smuggling of betel nut and black pepper of foreign origin - The Appellate Tribunal observed that while the ARDF report suggested the goods might be of Indonesian origin, it was not conclusively proven. As there was no definitive evidence establishing the goods as smuggled or foreign in origin beyond the ARDF report, the Tribunal held that the Revenue failed to discharge the onus to prove the goods' nature. Consequently, the Tribunal set aside the penalties imposed on the appellants, ruling in their favor.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4921 
