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...
The Tribunal held that its earlier provisional release order under Section 110A was an interim arrangement balancing both sides and had already contemplated movement of goods from an SEZ unit to another SEZ unit, an EOU, or the DTA, as well as return-linked adjustment of the bank guarantee. The contingency later projected by the applicant was therefore not an apparent mistake on the record, and the plea of possible double duty did not justify rectification. Any operational difficulty in applying the release conditions could only be addressed by clarification, not by review through a ROM application. The rectification request was dismissed, while the Tribunal directed expeditious completion of the investigation.
The Tribunal held that its earlier provisional release order under Section 110A was an interim arrangement balancing both sides and had already contemplated movement of goods from an SEZ unit to another SEZ unit, an EOU, or the DTA, as well as return-linked adjustment of the bank guarantee. The contingency later projected by the applicant was therefore not an apparent mistake on the record, and the plea of possible double duty did not justify rectification. Any operational difficulty in applying the release conditions could only be addressed by clarification, not by review through a ROM application. The rectification request was dismissed, while the Tribunal directed expeditious completion of the investigation.
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TaxTMI 
TaxTMI 
of 4918 
