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...
Customs Tribunal held that restrictions on import of new vehicles through designated ports under Foreign Trade Policy do not apply to vehicles imported in completely knocked down (CKD) condition. Expression 'motor vehicles' in relevant policy condition includes only completely built units, not CKD condition vehicles. Rule 126 of Central Motor Vehicle Rules requires prototype testing and approval, which is not possible for unassembled CKD vehicles. Relying on Delhi High Court judgment, Tribunal observed that term 'motor vehicle' in policy conditions can only apply to complete vehicles, not CKD or incomplete vehicles. Importing motorcycles in CKD condition through non-designated ICD did not violate any prohibition, hence no confiscation, redemption fine or penalty was imposable. Impugned order set aside, appeal allowed.
Customs Tribunal held that restrictions on import of new vehicles through designated ports under Foreign Trade Policy do not apply to vehicles imported in completely knocked down (CKD) condition. Expression 'motor vehicles' in relevant policy condition includes only completely built units, not CKD condition vehicles. Rule 126 of Central Motor Vehicle Rules requires prototype testing and approval, which is not possible for unassembled CKD vehicles. Relying on Delhi High Court judgment, Tribunal observed that term 'motor vehicle' in policy conditions can only apply to complete vehicles, not CKD or incomplete vehicles. Importing motorcycles in CKD condition through non-designated ICD did not violate any prohibition, hence no confiscation, redemption fine or penalty was imposable. Impugned order set aside, appeal allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4921 
