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...
HC quashed customs authorities' orders declining export drawback claims under Section 75 of Customs Act, 1962. Petitioner sought drawbacks for exports where realization of proceeds exceeded stipulated timeframe under Rule 16A. Customs rejected claims citing delayed realization without considering AD-I bank's regularization documents. Court held that AD Category-I banks possess authority to extend time limits for export proceeds realization, not exclusively RBI. Documentary evidence including bank's regularization certificate and export repatriation confirmation required proper examination to determine if receipts fell within extended period. Matter remanded to customs authorities for fresh consideration incorporating all relevant documents and specific reference to bank's extension powers under Rule 16A framework.
HC quashed customs authorities' orders declining export drawback claims under Section 75 of Customs Act, 1962. Petitioner sought drawbacks for exports where realization of proceeds exceeded stipulated timeframe under Rule 16A. Customs rejected claims citing delayed realization without considering AD-I bank's regularization documents. Court held that AD Category-I banks possess authority to extend time limits for export proceeds realization, not exclusively RBI. Documentary evidence including bank's regularization certificate and export repatriation confirmation required proper examination to determine if receipts fell within extended period. Matter remanded to customs authorities for fresh consideration incorporating all relevant documents and specific reference to bank's extension powers under Rule 16A framework.
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