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...
Appellants' right to challenge the enhancement of declared values for imported goods, even after initially requesting expedited clearance. The key points are: Section 17 of the Customs Act mandates a speaking order for reassessment at variance with self-assessment. Mere requests for expedited clearance cannot be construed as abandonment of the right to appeal reassessment. The proper officer must provide reasons for rejecting declared values before reassessment. Enhancing values solely based on NIDB data without corroborative evidence is unwarranted. Reassessment must comply with rules, be reasoned, and based on tangible justifiable material. The High Court allowed the appeals, setting aside CESTAT orders and restoring the Commissioner (Appeals) order.
Appellants' right to challenge the enhancement of declared values for imported goods, even after initially requesting expedited clearance. The key points are: Section 17 of the Customs Act mandates a speaking order for reassessment at variance with self-assessment. Mere requests for expedited clearance cannot be construed as abandonment of the right to appeal reassessment. The proper officer must provide reasons for rejecting declared values before reassessment. Enhancing values solely based on NIDB data without corroborative evidence is unwarranted. Reassessment must comply with rules, be reasoned, and based on tangible justifiable material. The High Court allowed the appeals, setting aside CESTAT orders and restoring the Commissioner (Appeals) order.
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