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...
Goods manufactured as health and nutritional supplements were classified under CTH 21069099 as food mixes, and assessment on retail sale price basis with 35% abatement was upheld. The Tribunal held that the notification benefit could be available in principle, but only on strict verification of the condition that no Cenvat credit was availed on inputs or input services; the matter was remanded for that limited verification and fresh quantification. It also held that complete non-registration and non-filing of excise returns constituted suppression with intent to evade duty, so the extended period and penalty liability were sustained, with penalty quantum left for re-determination in remand.
Goods manufactured as health and nutritional supplements were classified under CTH 21069099 as food mixes, and assessment on retail sale price basis with 35% abatement was upheld. The Tribunal held that the notification benefit could be available in principle, but only on strict verification of the condition that no Cenvat credit was availed on inputs or input services; the matter was remanded for that limited verification and fresh quantification. It also held that complete non-registration and non-filing of excise returns constituted suppression with intent to evade duty, so the extended period and penalty liability were sustained, with penalty quantum left for re-determination in remand.
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