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...
Admissibility of electronic printouts and statements recorded under section 108 in customs valuation was the central issue. Tribunal found absence of evidence about how printouts were produced, lack of certificates and no recording in Panchnamas meant the printouts could not be relied upon for undervaluation findings, so the re-determination of transaction value, differential duty and penalties could not be sustained; consequently the impugned reassessment and related demands/penalties were set aside and the appeals allowed.
Admissibility of electronic printouts and statements recorded under section 108 in customs valuation was the central issue. Tribunal found absence of evidence about how printouts were produced, lack of certificates and no recording in Panchnamas meant the printouts could not be relied upon for undervaluation findings, so the re-determination of transaction value, differential duty and penalties could not be sustained; consequently the impugned reassessment and related demands/penalties were set aside and the appeals allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
