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...
Provisional preservation of areca nuts did not make the goods classifiable under heading 0812, because that heading applies only to goods that remain unsuitable for immediate consumption in that state. Relying on the reasoning in S. Krishna & Co., the Court held that the imported goods did not satisfy that condition and were therefore classifiable under tariff item 0802, not 0812. The substantial question on tariff classification was answered in favour of the department, and the appeal was allowed.
Provisional preservation of areca nuts did not make the goods classifiable under heading 0812, because that heading applies only to goods that remain unsuitable for immediate consumption in that state. Relying on the reasoning in S. Krishna & Co., the Court held that the imported goods did not satisfy that condition and were therefore classifiable under tariff item 0802, not 0812. The substantial question on tariff classification was answered in favour of the department, and the appeal was allowed.
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