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...
Seizure - Burden of proof - ‘reasonable belief’ - Onus for proving the goods to be not smuggled - Seizure outside the ‘customs area’ - The Tribunal noted that the burden of proof does indeed shift to the person from whose possession the goods were seized under section 123, emphasizing the necessity of proving that the goods were not smuggled. The Tribunal confirmed the confiscation under section 111 was justified based on the evidence presented, including the frequency of travel by the Main Accused and the nature of the goods being consistent with smuggling activities. The evidence from electronic devices and a diary supported the assumption of smuggling.
Seizure - Burden of proof - ‘reasonable belief’ - Onus for proving the goods to be not smuggled - Seizure outside the ‘customs area’ - The Tribunal noted that the burden of proof does indeed shift to the person from whose possession the goods were seized under section 123, emphasizing the necessity of proving that the goods were not smuggled. The Tribunal confirmed the confiscation under section 111 was justified based on the evidence presented, including the frequency of travel by the Main Accused and the nature of the goods being consistent with smuggling activities. The evidence from electronic devices and a diary supported the assumption of smuggling.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
