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...
The High Court quashed the impugned orders denying refund application, based on the respondents' clarification that refund would not be denied if export proceeds are realized in Indian Rupees routed through a non-resident bank's freely convertible Vostro account outside the Asian Clearing Union or Nepal and Bhutan. However, the respondents contended that the applicability of the clarificatory circular to all exports or specific commodities required examination, and this aspect was kept open for verification by the respondents.
The High Court quashed the impugned orders denying refund application, based on the respondents' clarification that refund would not be denied if export proceeds are realized in Indian Rupees routed through a non-resident bank's freely convertible Vostro account outside the Asian Clearing Union or Nepal and Bhutan. However, the respondents contended that the applicability of the clarificatory circular to all exports or specific commodities required examination, and this aspect was kept open for verification by the respondents.
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