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...
The Supreme Court dismissed the appeal filed by the appellant Revenue, challenging the confiscation and penalty imposed for alleged violation of exemption conditions under notification N/N. 146/94-Cus. The issue concerned the sale of imported arms and ammunition to State Rifle Associations and District Clubs rather than direct use in national or international competitions. The tribunal had held that the exemption did not impose an "Actual User" condition and that the goods were used for the intended purpose. The Court concurred with this finding, concluding that no violation of the exemption conditions occurred. Consequently, the appeal was dismissed for lack of merit, affirming the tribunal's decision and upholding the legality of the impugned order.
The Supreme Court dismissed the appeal filed by the appellant Revenue, challenging the confiscation and penalty imposed for alleged violation of exemption conditions under notification N/N. 146/94-Cus. The issue concerned the sale of imported arms and ammunition to State Rifle Associations and District Clubs rather than direct use in national or international competitions. The tribunal had held that the exemption did not impose an "Actual User" condition and that the goods were used for the intended purpose. The Court concurred with this finding, concluding that no violation of the exemption conditions occurred. Consequently, the appeal was dismissed for lack of merit, affirming the tribunal's decision and upholding the legality of the impugned order.
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