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...
Customs and food-safety legislation operate concurrently: border control, tariff classification, valuation and anti-fraud enforcement remain within Customs powers, while food-safety compliance is regulated separately. A Customs Proper Officer may draw samples of imported food before Bill of Entry routing through FICS for Customs examination and investigation; routine FSSAI sampling does not create exclusive jurisdiction. Executive instructions cannot restrict statutory Customs powers. Challenges to sampling, testing methods, chain of custody and laboratory-report admissibility should be resolved in show-cause adjudication. Judicial review should not prematurely quash those processes or impose fresh-sampling, testing, cargo-release, or charge-waiver directions beyond the writ relief sought.
Customs and food-safety legislation operate concurrently: border control, tariff classification, valuation and anti-fraud enforcement remain within Customs powers, while food-safety compliance is regulated separately. A Customs Proper Officer may draw samples of imported food before Bill of Entry routing through FICS for Customs examination and investigation; routine FSSAI sampling does not create exclusive jurisdiction. Executive instructions cannot restrict statutory Customs powers. Challenges to sampling, testing methods, chain of custody and laboratory-report admissibility should be resolved in show-cause adjudication. Judicial review should not prematurely quash those processes or impose fresh-sampling, testing, cargo-release, or charge-waiver directions beyond the writ relief sought.
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