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...
Refund of Additional Duty of Customs (CVD) demanded from respondent after GST introduction on imported goods - refund of duty paid on re-import - time limitation. Commissioner (Appeals) granted refund. Respondent not liable to pay CVD after GST implementation from 01.07.2007, but paid due to system error and appellant's insistence. Section 26A limitation not applicable as provisions governing re-import duty payment per Notification No. 46/2017 dated 30.06.2017. Once respondent paid drawback with interest as per Notification, not liable for demanded duty. Appeal dismissed.
Refund of Additional Duty of Customs (CVD) demanded from respondent after GST introduction on imported goods - refund of duty paid on re-import - time limitation. Commissioner (Appeals) granted refund. Respondent not liable to pay CVD after GST implementation from 01.07.2007, but paid due to system error and appellant's insistence. Section 26A limitation not applicable as provisions governing re-import duty payment per Notification No. 46/2017 dated 30.06.2017. Once respondent paid drawback with interest as per Notification, not liable for demanded duty. Appeal dismissed.
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TaxTMI 
TaxTMI 
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