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...
Appellant engaged in manufacturing cosmetics and Vaseline, classifiable under Chapters 33 and 27 of CETA respectively. Appellant paid differential duty along with duty for January 2012, fulfilling conditions of Notification No. 20/2007-CE as amended. Lower authorities rejected refund of self-credit claimed by appellant to the extent of 56% of differential duty paid, citing non-compliance with Paragraph 2A. However, appellant paid duty for August 2011 to December 2011 in January 2012 as directed, making self-credit claim valid. Impugned order rejecting refund of self-credit to the extent of Rs. 10,27,377/- set aside by Appellate Tribunal, allowing appeal.
Appellant engaged in manufacturing cosmetics and Vaseline, classifiable under Chapters 33 and 27 of CETA respectively. Appellant paid differential duty along with duty for January 2012, fulfilling conditions of Notification No. 20/2007-CE as amended. Lower authorities rejected refund of self-credit claimed by appellant to the extent of 56% of differential duty paid, citing non-compliance with Paragraph 2A. However, appellant paid duty for August 2011 to December 2011 in January 2012 as directed, making self-credit claim valid. Impugned order rejecting refund of self-credit to the extent of Rs. 10,27,377/- set aside by Appellate Tribunal, allowing appeal.
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