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...
HC held that seizure under Customs Act s.110(1) requires proper officer to record specific written reasons demonstrating belief that goods are liable for confiscation. Mere citation of statutory provisions without explaining their applicability is insufficient. While the seizure memo was quashed for lacking detailed grounds, the show cause notice was sustained. The court emphasized that goods must be returned if notice under s.124(a) is not issued within 6 months of seizure, subject to valid extensions. Though provisional release occurred after 6 months with two 3-month extensions, investigation can proceed under Customs Act despite invalidation of seizure. The ruling balances procedural safeguards with enforcement powers.
HC held that seizure under Customs Act s.110(1) requires proper officer to record specific written reasons demonstrating belief that goods are liable for confiscation. Mere citation of statutory provisions without explaining their applicability is insufficient. While the seizure memo was quashed for lacking detailed grounds, the show cause notice was sustained. The court emphasized that goods must be returned if notice under s.124(a) is not issued within 6 months of seizure, subject to valid extensions. Though provisional release occurred after 6 months with two 3-month extensions, investigation can proceed under Customs Act despite invalidation of seizure. The ruling balances procedural safeguards with enforcement powers.
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