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...
Challenge concerned imposition of penalty on a customs broker for alleged mis-declaration, overvaluation and aiding illegal importation. Court found no finding of mens rea, complicity, fraud or prior knowledge connecting the broker to the offences and held the penal provisions were misapplied. Advisory guidance cited that penalties cannot attach where no evidence of complicity exists. The authority had regulatory alternatives (license suspension or revocation) which it did not pursue. The High Court invoked inherent constitutional jurisdiction to set aside the penalty and allowed the writ petition.
Challenge concerned imposition of penalty on a customs broker for alleged mis-declaration, overvaluation and aiding illegal importation. Court found no finding of mens rea, complicity, fraud or prior knowledge connecting the broker to the offences and held the penal provisions were misapplied. Advisory guidance cited that penalties cannot attach where no evidence of complicity exists. The authority had regulatory alternatives (license suspension or revocation) which it did not pursue. The High Court invoked inherent constitutional jurisdiction to set aside the penalty and allowed the writ petition.
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TaxTMI 
TaxTMI 
of 4918 
