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...
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Availability of a statutory revision in baggage confiscation matters may warrant declining writ jurisdiction where alleged procedural breaches depend on disputed facts. Although an alternative remedy does not automatically preclude a writ petition alleging natural justice or jurisdictional defects, disputes over waiver of written notice, oral notice, the alleged statement and voluntariness of contemporaneous documents require factual examination in revision. The writ petition challenging confiscation of a gold bar and consequential penalty was not entertained, with merits left open for statutory revision. A revision filed within the stipulated period could not be rejected merely because the petitioner had first approached the High Court.
Availability of a statutory revision in baggage confiscation matters may warrant declining writ jurisdiction where alleged procedural breaches depend on disputed facts. Although an alternative remedy does not automatically preclude a writ petition alleging natural justice or jurisdictional defects, disputes over waiver of written notice, oral notice, the alleged statement and voluntariness of contemporaneous documents require factual examination in revision. The writ petition challenging confiscation of a gold bar and consequential penalty was not entertained, with merits left open for statutory revision. A revision filed within the stipulated period could not be rejected merely because the petitioner had first approached the High Court.
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