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...
CESTAT denied exemption under Notification No.12/2012-Cus for imported Coke Breeze, upholding that metallurgical coke and coke breeze are distinct products with different characteristics and applications. Following precedent in Company A case, the Tribunal emphasized that coke breeze, being a byproduct of coke manufacture, cannot be equated with metallurgical coke used in blast furnaces. The significant price difference and distinct product characteristics preclude extending the notification benefits meant for metallurgical coke to coke breeze imports. The interpretation of exemption notification was deemed irrelevant given the fundamental product differences. Appeal dismissed, confirming differential treatment for customs duty purposes.
CESTAT denied exemption under Notification No.12/2012-Cus for imported Coke Breeze, upholding that metallurgical coke and coke breeze are distinct products with different characteristics and applications. Following precedent in Company A case, the Tribunal emphasized that coke breeze, being a byproduct of coke manufacture, cannot be equated with metallurgical coke used in blast furnaces. The significant price difference and distinct product characteristics preclude extending the notification benefits meant for metallurgical coke to coke breeze imports. The interpretation of exemption notification was deemed irrelevant given the fundamental product differences. Appeal dismissed, confirming differential treatment for customs duty purposes.
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