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...
Two conflicting orders-in-original were issued by the same authority for the same shipment and duty drawback claim, reflecting total non-application of mind and legal infirmity. Once the earlier order-in-original was found unsustainable, the later order-in-original could not independently survive and was liable to be treated as a nullity because two inconsistent adjudications cannot coexist on the same claim. Accordingly, both orders-in-original and consequential communications/notices were quashed, and the matter was remanded for fresh adjudication on merits under the Customs Act, after following due procedure and principles of natural justice, within a fixed timeframe. - HC
Two conflicting orders-in-original were issued by the same authority for the same shipment and duty drawback claim, reflecting total non-application of mind and legal infirmity. Once the earlier order-in-original was found unsustainable, the later order-in-original could not independently survive and was liable to be treated as a nullity because two inconsistent adjudications cannot coexist on the same claim. Accordingly, both orders-in-original and consequential communications/notices were quashed, and the matter was remanded for fresh adjudication on merits under the Customs Act, after following due procedure and principles of natural justice, within a fixed timeframe. - HC
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TaxTMI 
TaxTMI 
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