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 dismissed the appeals, sustaining invocation of the extended period of limitation and upholding denial of relief where the appellant relied on manipulated/forged Transport/Registration Authorizations (TRAs). The Tribunal held that the appellant's plea of ignorance of manipulation was untenable because statutory procedure required procurement of TRAs from the port of registration and verification of their authenticity; failure to apply to the issuing port and to verify documents constituted lack of due diligence. Consequently, the forgery of TRAs could not absolve the appellant, and relief was refused with appeals dismissed.
CESTAT dismissed the appeals, sustaining invocation of the extended period of limitation and upholding denial of relief where the appellant relied on manipulated/forged Transport/Registration Authorizations (TRAs). The Tribunal held that the appellant's plea of ignorance of manipulation was untenable because statutory procedure required procurement of TRAs from the port of registration and verification of their authenticity; failure to apply to the issuing port and to verify documents constituted lack of due diligence. Consequently, the forgery of TRAs could not absolve the appellant, and relief was refused with appeals dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
