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...
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CESTAT adjudicated a customs dispute regarding imported dry dates' country of origin. The tribunal determined that packing material and circumstantial evidence cannot conclusively establish goods' origin. Documentary evidence including Certificate of Origin from Dubai Chamber of Commerce & Industry, Bill of Lading, and commercial invoices substantiated United Arab Emirates as the legitimate country of origin. The tribunal rejected re-assessment findings proposing Pakistan origin, finding insufficient documentary proof. Consequently, the original assessment order was set aside, and the importer's appeal was allowed, emphasizing that packaging materials alone cannot definitively determine product origin.
CESTAT adjudicated a customs dispute regarding imported dry dates' country of origin. The tribunal determined that packing material and circumstantial evidence cannot conclusively establish goods' origin. Documentary evidence including Certificate of Origin from Dubai Chamber of Commerce & Industry, Bill of Lading, and commercial invoices substantiated United Arab Emirates as the legitimate country of origin. The tribunal rejected re-assessment findings proposing Pakistan origin, finding insufficient documentary proof. Consequently, the original assessment order was set aside, and the importer's appeal was allowed, emphasizing that packaging materials alone cannot definitively determine product origin.
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