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...
Demand proceedings for customs duty could not be sustained where the Bills of Entry assessments had not been challenged. The Tribunal held that the Revenue was seeking to dispute the exemption benefit granted at assessment, but the foundational issue was whether any demand action could proceed without first assailing the self-assessment itself. As the assessments had admittedly attained finality and remained unchallenged, the subsequent proceedings against the importer were unsustainable. The impugned order was upheld and the Revenue's appeals were dismissed.
Demand proceedings for customs duty could not be sustained where the Bills of Entry assessments had not been challenged. The Tribunal held that the Revenue was seeking to dispute the exemption benefit granted at assessment, but the foundational issue was whether any demand action could proceed without first assailing the self-assessment itself. As the assessments had admittedly attained finality and remained unchallenged, the subsequent proceedings against the importer were unsustainable. The impugned order was upheld and the Revenue's appeals were dismissed.
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