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...
Article 226 writ jurisdiction does not ordinarily permit a party to bypass an efficacious customs appellate remedy or its statutory limitation period. Allegations of coercion, waiver of written notice or personal hearing, service of the adjudication order, and procedural non-compliance may require factual determination in the statutory appeal unless they establish a patent jurisdictional defect or clear denial of natural justice. Substantial delay in invoking writ jurisdiction further weighs against intervention. A delayed customs writ was dismissed, with confiscation, penalty, and the evidentiary effect of relevant documents left open for determination by the competent appellate forum.
Article 226 writ jurisdiction does not ordinarily permit a party to bypass an efficacious customs appellate remedy or its statutory limitation period. Allegations of coercion, waiver of written notice or personal hearing, service of the adjudication order, and procedural non-compliance may require factual determination in the statutory appeal unless they establish a patent jurisdictional defect or clear denial of natural justice. Substantial delay in invoking writ jurisdiction further weighs against intervention. A delayed customs writ was dismissed, with confiscation, penalty, and the evidentiary effect of relevant documents left open for determination by the competent appellate forum.
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TaxTMI 
TaxTMI 
of 4918 
