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...
Extended limitation could not support recovery of Special Additional Duty on goods transferred from an FTWZ to a domestic tariff area unit because the exemption practice followed directions and decisions of SEZ and FTWZ authorities, including a chartered accountant's certificate. The Tribunal found no mala fides or suppression of facts intended to evade duty. As the entire demand lay outside the normal limitation period, the extended period was unavailable and the exemption's merits required no examination. The duty demand, confiscation and penalties were set aside, and Revenue's penalty-enhancement appeal was dismissed.
Extended limitation could not support recovery of Special Additional Duty on goods transferred from an FTWZ to a domestic tariff area unit because the exemption practice followed directions and decisions of SEZ and FTWZ authorities, including a chartered accountant's certificate. The Tribunal found no mala fides or suppression of facts intended to evade duty. As the entire demand lay outside the normal limitation period, the extended period was unavailable and the exemption's merits required no examination. The duty demand, confiscation and penalties were set aside, and Revenue's penalty-enhancement appeal was dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
