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...
Levy of safeguard duty - Determination of effective date and time of implementation of Notification - The appellant argued that the notification was only effective from its publication date in the Official Gazette, which was 24.02.2013. The Tribunal considered various judicial precedents and concluded that a notification becomes effective only upon its publication in the Official Gazette. Since the appellant’s goods were imported before the publication date, the safeguard duty could not be imposed.
Levy of safeguard duty - Determination of effective date and time of implementation of Notification - The appellant argued that the notification was only effective from its publication date in the Official Gazette, which was 24.02.2013. The Tribunal considered various judicial precedents and concluded that a notification becomes effective only upon its publication in the Official Gazette. Since the appellant’s goods were imported before the publication date, the safeguard duty could not be imposed.
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