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 dismissed the petition and upheld the detention and seizure of goods, holding that the impounding was founded on a contemporaneous, categorical statement by the vehicle driver that contradicted the documentary route claim. The Court found the driver's first-instance statement unrebutted, not procured under duress, and more probative than subsequent explanations; absence of any challenge to the statement's voluntariness or authenticity precluded its discredit. Consequently, the impugned orders were not arbitrary and the documentary evidence purporting a different origin was deemed unhelpful to the petitioner. Relief was refused and the administrative seizure and related orders affirmed.
HC dismissed the petition and upheld the detention and seizure of goods, holding that the impounding was founded on a contemporaneous, categorical statement by the vehicle driver that contradicted the documentary route claim. The Court found the driver's first-instance statement unrebutted, not procured under duress, and more probative than subsequent explanations; absence of any challenge to the statement's voluntariness or authenticity precluded its discredit. Consequently, the impugned orders were not arbitrary and the documentary evidence purporting a different origin was deemed unhelpful to the petitioner. Relief was refused and the administrative seizure and related orders affirmed.
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