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...
The case involved a dispute over a refund claim u/s 11B of the Central Excise Act. The Appellate Tribunal held that the time limitation for filing the refund claim did not apply as the duty was paid under protest. The Tribunal also ruled that the refund claims were valid even though the assessment of bills of entry was not challenged. The Revenue's argument that the refund claims were not maintainable without challenging the assessment was rejected. The Tribunal dismissed the Revenue's appeals, finding no merit in their arguments.
The case involved a dispute over a refund claim u/s 11B of the Central Excise Act. The Appellate Tribunal held that the time limitation for filing the refund claim did not apply as the duty was paid under protest. The Tribunal also ruled that the refund claims were valid even though the assessment of bills of entry was not challenged. The Revenue's argument that the refund claims were not maintainable without challenging the assessment was rejected. The Tribunal dismissed the Revenue's appeals, finding no merit in their arguments.
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