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...
Appellant's refund claims for excess duty paid on CPC exports were rejected by CESTAT. The Shipping Bills had been finally assessed incorporating Cess/Cesses, but refund claims were filed beyond the prescribed timeline under Section 27 of the Customs Act. The appellant neither paid under protest nor appealed the original assessments. CESTAT affirmed that refund claims cannot substitute appeal proceedings, and assessment orders must be challenged through proper appeal channels. The Tribunal rejected appellant's attempt to invoke Sections 149 and 154, finding no clerical/arithmetical errors in the assessment, as the Cess was incorporated through conscious action by both parties. The appeal was dismissed, upholding the lower authority's order.
Appellant's refund claims for excess duty paid on CPC exports were rejected by CESTAT. The Shipping Bills had been finally assessed incorporating Cess/Cesses, but refund claims were filed beyond the prescribed timeline under Section 27 of the Customs Act. The appellant neither paid under protest nor appealed the original assessments. CESTAT affirmed that refund claims cannot substitute appeal proceedings, and assessment orders must be challenged through proper appeal channels. The Tribunal rejected appellant's attempt to invoke Sections 149 and 154, finding no clerical/arithmetical errors in the assessment, as the Cess was incorporated through conscious action by both parties. The appeal was dismissed, upholding the lower authority's order.
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