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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CESTAT held that appellant-importer is liable to pay interest for delayed payment of SAD u/s 28AB of Customs Act, 1962. However, penalties imposed on appellant-importer u/ss 114A and 114AA, and on CHA u/s 112(a)(ii) were set aside as conditions for invoking these provisions were not met. Confiscation of imported goods was denied as goods were cleared after due permission. Proceedings against company officials were rightly dropped by adjudicating authority. Interest already paid by appellant-importer to be appropriated against interest liability. Appeals disposed of accordingly.
CESTAT held that appellant-importer is liable to pay interest for delayed payment of SAD u/s 28AB of Customs Act, 1962. However, penalties imposed on appellant-importer u/ss 114A and 114AA, and on CHA u/s 112(a)(ii) were set aside as conditions for invoking these provisions were not met. Confiscation of imported goods was denied as goods were cleared after due permission. Proceedings against company officials were rightly dropped by adjudicating authority. Interest already paid by appellant-importer to be appropriated against interest liability. Appeals disposed of accordingly.
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