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...
CESTAT allowed the appeal against denial of rectification under Section 154 of the Customs Act, 1962, holding that the accidental omission by the assessing officer in finalizing shipping bills by determining "Fe" content on DMT instead of WMT basis constituted an error requiring rectification. Following precedents in Sesa Goa Limited and Vedanta Limited cases, the Tribunal ruled that "omission" should not be interpreted restrictively but should encompass errors arising from such omissions. The adjudicating authority was directed to rectify the finalization of provisional assessment for calculation of "Fe" content on WMT basis per the Supreme Court's decision in Gangadhar Narsingdas Aggarwal and pass a speaking order within one month.
CESTAT allowed the appeal against denial of rectification under Section 154 of the Customs Act, 1962, holding that the accidental omission by the assessing officer in finalizing shipping bills by determining "Fe" content on DMT instead of WMT basis constituted an error requiring rectification. Following precedents in Sesa Goa Limited and Vedanta Limited cases, the Tribunal ruled that "omission" should not be interpreted restrictively but should encompass errors arising from such omissions. The adjudicating authority was directed to rectify the finalization of provisional assessment for calculation of "Fe" content on WMT basis per the Supreme Court's decision in Gangadhar Narsingdas Aggarwal and pass a speaking order within one month.
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