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...
n-Hexane was classified as a separate chemically defined compound under Chapter 29 rather than as petroleum oil or motor spirit under Chapter 27. The Court held that the Revenue bore the burden of proving Chapter 27 classification and failed to show that the product satisfied all motor spirit conditions, including suitability for use as fuel in spark ignition engines. Applying Rule 3(a) of the General Rules of Interpretation, it preferred the more specific HSN description for hexane as an acyclic saturated hydrocarbon. It further found that manufacturing impurities did not convert the product into a mixture, and relied on the DGFT circular supporting Chapter 29 treatment. The Revenue's classification claim was rejected.
n-Hexane was classified as a separate chemically defined compound under Chapter 29 rather than as petroleum oil or motor spirit under Chapter 27. The Court held that the Revenue bore the burden of proving Chapter 27 classification and failed to show that the product satisfied all motor spirit conditions, including suitability for use as fuel in spark ignition engines. Applying Rule 3(a) of the General Rules of Interpretation, it preferred the more specific HSN description for hexane as an acyclic saturated hydrocarbon. It further found that manufacturing impurities did not convert the product into a mixture, and relied on the DGFT circular supporting Chapter 29 treatment. The Revenue's classification claim was rejected.
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TaxTMI 
TaxTMI 
of 4918 
