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 allowed the appeal, holding that the refund claim for anti-dumping duty was filed within the statutory six-month limitation period prescribed by Section 27 of the Customs Act, 1962. The Tribunal found that the appellant's submission of documents and refund application was timely, and this assertion was not contested by either the Appellate Authority or the department. Consequently, the finding that the claim was time-barred was deemed unsustainable. The portion of the impugned order denying the refund was set aside, and the original order sanctioning the refund of anti-dumping duty to the appellant was restored. The appeal was allowed in favor of the appellant.
CESTAT allowed the appeal, holding that the refund claim for anti-dumping duty was filed within the statutory six-month limitation period prescribed by Section 27 of the Customs Act, 1962. The Tribunal found that the appellant's submission of documents and refund application was timely, and this assertion was not contested by either the Appellate Authority or the department. Consequently, the finding that the claim was time-barred was deemed unsustainable. The portion of the impugned order denying the refund was set aside, and the original order sanctioning the refund of anti-dumping duty to the appellant was restored. The appeal was allowed in favor of the appellant.
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TaxTMI 
TaxTMI 
of 4918 
