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...
Penalty imposed u/s 112a(ii) of Customs Act for smuggling through mis-declaration and undervaluation. Extent of duty evasion uncertain but forensic evidence established undervaluation scale for past and current imports, benefiting importers and defrauding government dues. Appellants failed to justify penalty waiver. Digital mapping and forensic examination exposed racket. Considering facts, appellants' failure to discharge obligations, filing Bill of Entry based on unsigned invoices, penalty of Rs.4 lakh on company and Rs.1 lakh on individual upheld u/s 112(ii). Appeal disposed.
Penalty imposed u/s 112a(ii) of Customs Act for smuggling through mis-declaration and undervaluation. Extent of duty evasion uncertain but forensic evidence established undervaluation scale for past and current imports, benefiting importers and defrauding government dues. Appellants failed to justify penalty waiver. Digital mapping and forensic examination exposed racket. Considering facts, appellants' failure to discharge obligations, filing Bill of Entry based on unsigned invoices, penalty of Rs.4 lakh on company and Rs.1 lakh on individual upheld u/s 112(ii). Appeal disposed.
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