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...
The note addresses VCES eligibility where pre- and post-July 2012 liability arise from different legal questions: whether the appellant rendered an intellectual property service before July 2012 versus whether permitting Hallmarking/Assaying Centres to administer the BIS scheme for royalty constituted a 'service' after July 2012 under the post-July 2012 definition. It concludes that the issues are distinct, so the identical-issue proviso to the VCES does not bar acceptance of the later declaration; reliance on prior notices about intellectual property services did not preclude voluntary compliance for the separate charge based on the broader post-July 2012 service definition.
The note addresses VCES eligibility where pre- and post-July 2012 liability arise from different legal questions: whether the appellant rendered an intellectual property service before July 2012 versus whether permitting Hallmarking/Assaying Centres to administer the BIS scheme for royalty constituted a 'service' after July 2012 under the post-July 2012 definition. It concludes that the issues are distinct, so the identical-issue proviso to the VCES does not bar acceptance of the later declaration; reliance on prior notices about intellectual property services did not preclude voluntary compliance for the separate charge based on the broader post-July 2012 service definition.
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