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...
Refund claim of duty paid on short landing of imported goods. Unjust enrichment principle inapplicable as duty amount shown as receivable in books of accounts, certified by Chartered Accountant, indicating no passing of incidence. Tribunal's earlier decision in appellant's own case upheld, finding no unjust enrichment. Interest on refund payable from date after three months of filing refund application, following Supreme Court's landmark judgments. Impugned orders set aside, appeal allowed by Appellate Tribunal.
Refund claim of duty paid on short landing of imported goods. Unjust enrichment principle inapplicable as duty amount shown as receivable in books of accounts, certified by Chartered Accountant, indicating no passing of incidence. Tribunal's earlier decision in appellant's own case upheld, finding no unjust enrichment. Interest on refund payable from date after three months of filing refund application, following Supreme Court's landmark judgments. Impugned orders set aside, appeal allowed by Appellate Tribunal.
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TaxTMI 
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