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...
The HC directed that the Respondents decide the Petitioner's exemption application under the 19 Mar 2021 Circular (invoking Regulations 5(2) and 6(1)(o) of the Handling of Cargo in Customs Area Regulations, 2009) expeditiously, preferably within eight weeks of service of the order. Pending that decision, the Respondents were restrained from demanding further cost recovery charges from the Petitioner, a Container Freight Station and custodian under Section 45, for the relevant period. If found eligible, exemption shall be applied retrospectively from the date the application was finally made free of defects. The petition is disposed of.
The HC directed that the Respondents decide the Petitioner's exemption application under the 19 Mar 2021 Circular (invoking Regulations 5(2) and 6(1)(o) of the Handling of Cargo in Customs Area Regulations, 2009) expeditiously, preferably within eight weeks of service of the order. Pending that decision, the Respondents were restrained from demanding further cost recovery charges from the Petitioner, a Container Freight Station and custodian under Section 45, for the relevant period. If found eligible, exemption shall be applied retrospectively from the date the application was finally made free of defects. The petition is disposed of.
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TaxTMI 
TaxTMI 
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