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 upheld that the DGFT notification relied on powers under Sections 3 and 5 of the Foreign Trade (Development & Regulation) Act, 1992 and on paragraphs 1.02 and 2.01 of the FTP, recognising the Central Government's competence to amend the FTP and to regulate imports by prohibition or restriction. Notwithstanding this statutory foundation, the court found that the Petitioner established a strong prima facie case and granted ad-interim relief pendente lite, listing the matter for consideration of interim reliefs on 13 Nov 2025. The classification change and import prohibition remain subject to final adjudication.
The HC upheld that the DGFT notification relied on powers under Sections 3 and 5 of the Foreign Trade (Development & Regulation) Act, 1992 and on paragraphs 1.02 and 2.01 of the FTP, recognising the Central Government's competence to amend the FTP and to regulate imports by prohibition or restriction. Notwithstanding this statutory foundation, the court found that the Petitioner established a strong prima facie case and granted ad-interim relief pendente lite, listing the matter for consideration of interim reliefs on 13 Nov 2025. The classification change and import prohibition remain subject to final adjudication.
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