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...
HC ruled customs authorities improperly disposed of 1065.10 grams of detained gold without adequate notice to petitioner. The department's undated communication lacked proof of delivery and proper authentication. Finding the disposal contrary to law, including Circular dated September 6, 2022, the court determined all subsequent actions by customs (redemption fine, penalty, duty deductions) were untenable. Petitioner entitled to full current market value of gold, payable within three weeks, with Rs. 1,00,000 penalty for late payment. The disposal process violated procedural requirements and petitioner's rights, rendering customs department's entire handling of the matter legally deficient. Court directed CBIC's OSD (Legal) for compliance.
HC ruled customs authorities improperly disposed of 1065.10 grams of detained gold without adequate notice to petitioner. The department's undated communication lacked proof of delivery and proper authentication. Finding the disposal contrary to law, including Circular dated September 6, 2022, the court determined all subsequent actions by customs (redemption fine, penalty, duty deductions) were untenable. Petitioner entitled to full current market value of gold, payable within three weeks, with Rs. 1,00,000 penalty for late payment. The disposal process violated procedural requirements and petitioner's rights, rendering customs department's entire handling of the matter legally deficient. Court directed CBIC's OSD (Legal) for compliance.
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