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 HC held that absence of endorsement on the bills of lading did not automatically vitiate the sale contracts, as the parties were ad idem and no repudiation was pleaded; however, on the evidence the transactions were not proved to have been completed on the high seas because there was no proof of delivery of endorsed bills to the buyers offshore. Consequently the HC set aside the interim order in favour of the petitioner and clarified that the petitioner is liable to pay the market fee and penalty in respect of 9,000 metric tonnes of wheat as directed earlier; the writ petition is disposed of.
The HC held that absence of endorsement on the bills of lading did not automatically vitiate the sale contracts, as the parties were ad idem and no repudiation was pleaded; however, on the evidence the transactions were not proved to have been completed on the high seas because there was no proof of delivery of endorsed bills to the buyers offshore. Consequently the HC set aside the interim order in favour of the petitioner and clarified that the petitioner is liable to pay the market fee and penalty in respect of 9,000 metric tonnes of wheat as directed earlier; the writ petition is disposed of.
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