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 SC dismissed the appeal and upheld levy of tax under s.3F(1)(b) of the U.P. Trade Tax Act, 1948, holding that the appellant is liable to pay tax on ink and processing/packing materials used in printing. The Court applied the principle that transfer of property in goods occurs when goods are incorporated in the works, and rejected the "dominant intention" test for works contracts. Because the appellant failed to furnish an itemised breakdown, the Assessing Authority properly assessed value; chemically altered ink and constituent chemicals were held to be transferred as goods. All statutory conditions for levy under s.3F(1)(b) were found satisfied.
The SC dismissed the appeal and upheld levy of tax under s.3F(1)(b) of the U.P. Trade Tax Act, 1948, holding that the appellant is liable to pay tax on ink and processing/packing materials used in printing. The Court applied the principle that transfer of property in goods occurs when goods are incorporated in the works, and rejected the "dominant intention" test for works contracts. Because the appellant failed to furnish an itemised breakdown, the Assessing Authority properly assessed value; chemically altered ink and constituent chemicals were held to be transferred as goods. All statutory conditions for levy under s.3F(1)(b) were found satisfied.
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