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...
The HC dismissed the challenge to the intimation letter but modified its conditions for provisional release. The petitioner must remit the declared duty and pay 50% of the differential duty computed by the Department (total re-determined value Rs. 3,15,01,438; differential duty Rs. 1,43,21,357). The petitioner is ordered to execute a bond for Rs. 3,15,01,438 and an additional bond of Rs. 2,80,00,000 in lieu of a bank guarantee. On compliance with these conditions, the respondents shall release the goods within seven days. The adjudication proceedings under Section 110A of the Customs Act, 1962 remain pending. Petition disposed.
The HC dismissed the challenge to the intimation letter but modified its conditions for provisional release. The petitioner must remit the declared duty and pay 50% of the differential duty computed by the Department (total re-determined value Rs. 3,15,01,438; differential duty Rs. 1,43,21,357). The petitioner is ordered to execute a bond for Rs. 3,15,01,438 and an additional bond of Rs. 2,80,00,000 in lieu of a bank guarantee. On compliance with these conditions, the respondents shall release the goods within seven days. The adjudication proceedings under Section 110A of the Customs Act, 1962 remain pending. Petition disposed.
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