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 in part, holding that the appellants' claim that gherkins in brine must be included for computation of SION norms is sustainable and, in the absence of contrary findings, consumption of vinegar did not exceed permitted SION entitlements; accordingly the demand for customs and central excise duty, interest and penalty insofar as founded on alleged excess vinegar consumption is set aside. The demand in respect of HDPE barrels remains operative, as there is no contest on that issue and CESTAT declined interference. Having decided the substantive merits, the Tribunal found no need to examine extended limitation.
CESTAT allowed the appeal in part, holding that the appellants' claim that gherkins in brine must be included for computation of SION norms is sustainable and, in the absence of contrary findings, consumption of vinegar did not exceed permitted SION entitlements; accordingly the demand for customs and central excise duty, interest and penalty insofar as founded on alleged excess vinegar consumption is set aside. The demand in respect of HDPE barrels remains operative, as there is no contest on that issue and CESTAT declined interference. Having decided the substantive merits, the Tribunal found no need to examine extended limitation.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
