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...
Government departments remain equally bound by limitation requirements in Customs Act appeals. Vague assertions that earlier counsel caused delay do not establish sufficient cause where the department cannot explain file transfer, follow-up, retrieval, or inconsistencies over documents allegedly supplied. Administrative inaction, lethargic internal functioning, and an unsubstantiated effort to attribute delay wholly to counsel cannot justify condonation. In the absence of a reasonable explanation, the delay-condonation application was dismissed and the Customs Act appeal stood disposed of.
Government departments remain equally bound by limitation requirements in Customs Act appeals. Vague assertions that earlier counsel caused delay do not establish sufficient cause where the department cannot explain file transfer, follow-up, retrieval, or inconsistencies over documents allegedly supplied. Administrative inaction, lethargic internal functioning, and an unsubstantiated effort to attribute delay wholly to counsel cannot justify condonation. In the absence of a reasonable explanation, the delay-condonation application was dismissed and the Customs Act appeal stood disposed of.
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