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...
Interception and seizure of gold from an arriving passenger was upheld: officers acting on reasonable belief had jurisdiction to search and seize irrespective of exact point of interception. Possession of unmarked notified goods shifted the evidential burden to the possessor to prove lawful acquisition; absence of documentary proof and an un retracted admission sustained the statutory presumption of smuggling. Statements recorded under the customs evidence provision and assayer reports were admissible and, together with physical recovery and panchanama, furnished corroborative primary evidence. Denial of cross examination of panch witnesses was held non prejudicial on these facts and did not vitiate adjudication.
Interception and seizure of gold from an arriving passenger was upheld: officers acting on reasonable belief had jurisdiction to search and seize irrespective of exact point of interception. Possession of unmarked notified goods shifted the evidential burden to the possessor to prove lawful acquisition; absence of documentary proof and an un retracted admission sustained the statutory presumption of smuggling. Statements recorded under the customs evidence provision and assayer reports were admissible and, together with physical recovery and panchanama, furnished corroborative primary evidence. Denial of cross examination of panch witnesses was held non prejudicial on these facts and did not vitiate adjudication.
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