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...
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Parts of railway diesel locomotive classified under CETH 86079100. Allegation of wilful misclassification and intent to evade duty untenable. Misclassification not equated with misdeclaration. Bona fide adoption of classification by importer permissible as manufacturers not expected to be fully conversant with tariff schedules. Extended period of limitation and penalties set aside. Appeal allowed.
Parts of railway diesel locomotive classified under CETH 86079100. Allegation of wilful misclassification and intent to evade duty untenable. Misclassification not equated with misdeclaration. Bona fide adoption of classification by importer permissible as manufacturers not expected to be fully conversant with tariff schedules. Extended period of limitation and penalties set aside. Appeal allowed.
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