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...
CESTAT held that Rule 9(1)(b) of Cenvat Credit Rules, 2004 restricting Cenvat credit is applicable only for sale transactions, not stock transfers between units of same entity. Since transaction involved stock transfer and not sale, denial of Cenvat credit to appellant on supplementary invoice for duty paid on stock transfer was without authority of law. Appeal allowed.
CESTAT held that Rule 9(1)(b) of Cenvat Credit Rules, 2004 restricting Cenvat credit is applicable only for sale transactions, not stock transfers between units of same entity. Since transaction involved stock transfer and not sale, denial of Cenvat credit to appellant on supplementary invoice for duty paid on stock transfer was without authority of law. Appeal allowed.
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