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 dismissed Revenue's appeals challenging customs duty exemption. The tribunal found no merit in confiscating imported goods used for completed projects. The key legal determination centered on procedural irregularities in post-import conditions and notification amendments. Despite transferring goods to new projects without prior authorization, the respondent successfully argued that no bond/bank guarantee was originally required and the subsequent notification amendments could not retroactively impose conditions. The tribunal emphasized that goods unavailable for confiscation cannot be directed for seizure, effectively ruling in favor of the respondent and upholding their right to utilize imported equipment across different approved projects.
CESTAT dismissed Revenue's appeals challenging customs duty exemption. The tribunal found no merit in confiscating imported goods used for completed projects. The key legal determination centered on procedural irregularities in post-import conditions and notification amendments. Despite transferring goods to new projects without prior authorization, the respondent successfully argued that no bond/bank guarantee was originally required and the subsequent notification amendments could not retroactively impose conditions. The tribunal emphasized that goods unavailable for confiscation cannot be directed for seizure, effectively ruling in favor of the respondent and upholding their right to utilize imported equipment across different approved projects.
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