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...
The HC held that amendment of a shipping bill from "Free Shipping Bill" to "Shipping Bill for Claim for Drawback" regarding re-export of goods under Section 149 of the Customs Act was permissible. Since the imported Black Pepper was never allowed outside customs area and had already been tested per Food Safety and Standards Act requirements, re-examination before re-export would have been merely procedural. Procedural irregularities under the Re-export of Imported Goods Rules cannot prejudice the petitioner's rights, as procedures are "handmaids of justice." The court directed respondents to refund the amount within two months, ruling that the petitioner could not be denied substantial benefits where goods were exported without being cleared.
The HC held that amendment of a shipping bill from "Free Shipping Bill" to "Shipping Bill for Claim for Drawback" regarding re-export of goods under Section 149 of the Customs Act was permissible. Since the imported Black Pepper was never allowed outside customs area and had already been tested per Food Safety and Standards Act requirements, re-examination before re-export would have been merely procedural. Procedural irregularities under the Re-export of Imported Goods Rules cannot prejudice the petitioner's rights, as procedures are "handmaids of justice." The court directed respondents to refund the amount within two months, ruling that the petitioner could not be denied substantial benefits where goods were exported without being cleared.
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