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 dismissed appellant's plea regarding duty exemption on goods transferred for job work. The court rejected the revenue neutrality argument based on CENVAT credit entitlement, holding that such interpretation would undermine the entire CENVAT credit scheme. The notification's benefits ceased once goods left the factory premises, even for job work. The concurrent findings by adjudicating authority, appellate authority, and Tribunal established that duty payment was mandatory at the time of clearance, regardless of subsequent use in production. The appellant's admission of revenue neutrality itself proved duty liability, as there was no valid justification for non-payment when sending goods for job work as required by law.
HC dismissed appellant's plea regarding duty exemption on goods transferred for job work. The court rejected the revenue neutrality argument based on CENVAT credit entitlement, holding that such interpretation would undermine the entire CENVAT credit scheme. The notification's benefits ceased once goods left the factory premises, even for job work. The concurrent findings by adjudicating authority, appellate authority, and Tribunal established that duty payment was mandatory at the time of clearance, regardless of subsequent use in production. The appellant's admission of revenue neutrality itself proved duty liability, as there was no valid justification for non-payment when sending goods for job work as required by law.
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TaxTMI 
TaxTMI 
of 4918 
