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...
Contravention of Sections 8(3), 8(4), and 9(1)(b) of FERA established - illegal foreign exchange remittance abroad disguised as charges for imports that never occurred. Sections apply to 'person', not limited to 'importer'. Evidence showed appellant controlled firms receiving remittances despite claims of missing import documents. Customs reports confirmed no diamonds imported against remittances. Appellant orchestrated modus operandi for illegal remittances. Composite penalty upheld for contraventions by appellant and co-appellant. Appeals dismissed.
Contravention of Sections 8(3), 8(4), and 9(1)(b) of FERA established - illegal foreign exchange remittance abroad disguised as charges for imports that never occurred. Sections apply to 'person', not limited to 'importer'. Evidence showed appellant controlled firms receiving remittances despite claims of missing import documents. Customs reports confirmed no diamonds imported against remittances. Appellant orchestrated modus operandi for illegal remittances. Composite penalty upheld for contraventions by appellant and co-appellant. Appeals dismissed.
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TaxTMI 
TaxTMI 
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