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...
Exemption from Special Additional Duty under Notification No. 45/2005-Customs was held unavailable where imported bulk tablets were moved from an FTWZ to the importer's factory by stock transfer, because sale on payment of Sales Tax/VAT was a condition precedent and was not satisfied at the clearance stage. However, the demand was set aside as time-barred: the Tribunal found that the record disclosed the nature of the activity and the parties' understanding of the notification, so non-payment of duty could not be treated as suppression, wilful misstatement or similar conduct to justify the extended limitation period under Section 28. The appeals were allowed solely on limitation.
Exemption from Special Additional Duty under Notification No. 45/2005-Customs was held unavailable where imported bulk tablets were moved from an FTWZ to the importer's factory by stock transfer, because sale on payment of Sales Tax/VAT was a condition precedent and was not satisfied at the clearance stage. However, the demand was set aside as time-barred: the Tribunal found that the record disclosed the nature of the activity and the parties' understanding of the notification, so non-payment of duty could not be treated as suppression, wilful misstatement or similar conduct to justify the extended limitation period under Section 28. The appeals were allowed solely on limitation.
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