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...
CESTAT dismissed the rectification of mistake application filed by the appellant. It held that the Final Order had correctly recorded and relied upon the Textile Committee's test report dated 30.08.2016 and additional report dated 21.09.2016, both pertaining to the same sample received on 08.07.2016 under DRI's letter dated 06.07.2016. The contention that the additional report was based on a second set of samples sent on 01.09.2016 was rejected as contrary to the record. The Tribunal further reiterated that HS classification is a quasi-judicial function of customs authorities, not experts. No mistake apparent on record was found.
CESTAT dismissed the rectification of mistake application filed by the appellant. It held that the Final Order had correctly recorded and relied upon the Textile Committee's test report dated 30.08.2016 and additional report dated 21.09.2016, both pertaining to the same sample received on 08.07.2016 under DRI's letter dated 06.07.2016. The contention that the additional report was based on a second set of samples sent on 01.09.2016 was rejected as contrary to the record. The Tribunal further reiterated that HS classification is a quasi-judicial function of customs authorities, not experts. No mistake apparent on record was found.
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