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 adjudicated that the Show Cause Notice issued more than six years after export is time-barred under the Customs Act, 1962. The tribunal found significant procedural delays rendering the entire proceedings void, specifically noting that adjudication occurred eight years after the original export, which exceeds the prescribed five-year limitation period. The appellants' penalties were set aside due to unwarranted delays and lack of timely investigation. The decision reinforces that procedural limitations are critical in customs proceedings, and excessive administrative latches can invalidate potential penalties, even when potential fraudulent documentation is suspected.
CESTAT adjudicated that the Show Cause Notice issued more than six years after export is time-barred under the Customs Act, 1962. The tribunal found significant procedural delays rendering the entire proceedings void, specifically noting that adjudication occurred eight years after the original export, which exceeds the prescribed five-year limitation period. The appellants' penalties were set aside due to unwarranted delays and lack of timely investigation. The decision reinforces that procedural limitations are critical in customs proceedings, and excessive administrative latches can invalidate potential penalties, even when potential fraudulent documentation is suspected.
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TaxTMI 
TaxTMI 
of 4918 
