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...
Breach of an import undertaking under Condition No.104 (Serial No.347B) for a helicopter -- demonstrated by predominant private, unpaid use -- supports confiscation and recovery by recourse to the undertaking despite references to section 28. The tribunal upheld confiscation because the exemption condition was substantially violated. Penalties under section 112 were quashed for two officers because the impugned order did not establish their knowledge or mens rea that unpaid private use would violate the exemption; absence of culpable knowledge defeated individual penalty liability and the department's appeal against penalty enhancement was dismissed.
Breach of an import undertaking under Condition No.104 (Serial No.347B) for a helicopter -- demonstrated by predominant private, unpaid use -- supports confiscation and recovery by recourse to the undertaking despite references to section 28. The tribunal upheld confiscation because the exemption condition was substantially violated. Penalties under section 112 were quashed for two officers because the impugned order did not establish their knowledge or mens rea that unpaid private use would violate the exemption; absence of culpable knowledge defeated individual penalty liability and the department's appeal against penalty enhancement was dismissed.
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