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...
CESTAT allowed the appeal and set aside the impugned order, holding that the appellant validly availed benefit of N/N.46/2011-Cus. dated 01.06.2011 by presenting four distinct country-of-origin certificates at import. The Tribunal found no conclusive evidence to impugn the COOs, rejected demands founded on conjecture and e-mails, and held that COOs not sent for verification could not be invalidated by extrapolation from other verifications. The demand for differential duty of Rs.31,07,086 with interest was annulled, the goods were held not liable for confiscation, the redemption fine of Rs.3,00,000 under s.125 was set aside, and penalties under ss.114A and 114AA were held unsustainable.
CESTAT allowed the appeal and set aside the impugned order, holding that the appellant validly availed benefit of N/N.46/2011-Cus. dated 01.06.2011 by presenting four distinct country-of-origin certificates at import. The Tribunal found no conclusive evidence to impugn the COOs, rejected demands founded on conjecture and e-mails, and held that COOs not sent for verification could not be invalidated by extrapolation from other verifications. The demand for differential duty of Rs.31,07,086 with interest was annulled, the goods were held not liable for confiscation, the redemption fine of Rs.3,00,000 under s.125 was set aside, and penalties under ss.114A and 114AA were held unsustainable.
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TaxTMI 
TaxTMI 
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