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...
Appellant's undertaking and declaration of not being penalized under Customs Act or related laws was correct. Cancellation of Special Bonded Warehouse License u/s 58B and penalty u/s 117 of Customs Act were set aside. Relying on precedents, it was held that penalty imposed for contravention u/s 46 does not constitute an 'offence' under the Act. When two expressions are used in the same notification, different meanings must be assigned. The impugned order cancelling the license was unsustainable and the appeal was allowed.
Appellant's undertaking and declaration of not being penalized under Customs Act or related laws was correct. Cancellation of Special Bonded Warehouse License u/s 58B and penalty u/s 117 of Customs Act were set aside. Relying on precedents, it was held that penalty imposed for contravention u/s 46 does not constitute an 'offence' under the Act. When two expressions are used in the same notification, different meanings must be assigned. The impugned order cancelling the license was unsustainable and the appeal was allowed.
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