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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HC ruled in favor of appellant regarding condonation of delay in customs appeal. While Commissioner of Customs (Appeals) lacked authority to condone delay beyond 30 days, CESTAT erred in dismissing the subsequent appeal filed within statutory limits. Court found compelling reasons for delay, noting appellant's pending representation before third respondent on 22.08.2007 likely caused wait before filing appeal. CESTAT's cursory dismissal failed to consider relevant parameters. Questions of law on limitation resolved favorably, with exemption issue covered by previous CESTAT Bangalore ruling supporting appellant's position. Appeal succeeded with costs throughout.
HC ruled in favor of appellant regarding condonation of delay in customs appeal. While Commissioner of Customs (Appeals) lacked authority to condone delay beyond 30 days, CESTAT erred in dismissing the subsequent appeal filed within statutory limits. Court found compelling reasons for delay, noting appellant's pending representation before third respondent on 22.08.2007 likely caused wait before filing appeal. CESTAT's cursory dismissal failed to consider relevant parameters. Questions of law on limitation resolved favorably, with exemption issue covered by previous CESTAT Bangalore ruling supporting appellant's position. Appeal succeeded with costs throughout.
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