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 penalties u/ss 112(a) and 112(b) of the Customs Act for smuggling foreign gold. The tribunal held that statements without cross-examination are inadmissible. The appellant no. 2 wasn't actively involved in smuggling, so penalties were unsustainable. Appellant no. 1's implication lacked evidence and violated section 138B. Both appellants didn't claim gold ownership, so burden of proof u/s 123 didn't apply. Penalties u/ss 112(a) and 112(b) were unsupportable. Thus, penalties on both appellants were set aside, and the appeal was allowed.
The case involved penalties u/ss 112(a) and 112(b) of the Customs Act for smuggling foreign gold. The tribunal held that statements without cross-examination are inadmissible. The appellant no. 2 wasn't actively involved in smuggling, so penalties were unsustainable. Appellant no. 1's implication lacked evidence and violated section 138B. Both appellants didn't claim gold ownership, so burden of proof u/s 123 didn't apply. Penalties u/ss 112(a) and 112(b) were unsupportable. Thus, penalties on both appellants were set aside, and the appeal was allowed.
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