Regulatory consolidation for investment advisers: SEBI issues master circular consolidating guidance and prescribing compliance, reporting, fees and s...
Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
Extended limitation was held applicable because the investigation materials showed wilful misstatement and suppression of facts, including diversion of duty-free imports, use of an incorrect export code, and alleged manipulation of export documentation. The plea that the discrepancy was merely clerical was rejected, and the show cause notice was treated as timely. The requirement of pre-deposit was also upheld as reasonable because the appellants could not rely on parity with an earlier order involving different facts and limited bills of entry. On that basis, the direction to deposit amounts and the dismissal of the appeals for non-compliance were sustained.
Extended limitation was held applicable because the investigation materials showed wilful misstatement and suppression of facts, including diversion of duty-free imports, use of an incorrect export code, and alleged manipulation of export documentation. The plea that the discrepancy was merely clerical was rejected, and the show cause notice was treated as timely. The requirement of pre-deposit was also upheld as reasonable because the appellants could not rely on parity with an earlier order involving different facts and limited bills of entry. On that basis, the direction to deposit amounts and the dismissal of the appeals for non-compliance were sustained.
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