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Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
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The Tribunal interpreted Sl. No. 226 of Notification No. 1/2017-Integrated Tax (Rate) on a plain reading of the words "LED lights or fixtures including LED lamps" and held that "including" is a word of enlargement, not restriction. It rejected the narrower construction that would confine the benefit only to fixtures fitted with or containing LED lamps. On that interpretation, imported lighting fixtures were held eligible for the concessional rate, and the demand, interest and penalty raised on denial of the notification benefit were set aside.
The Tribunal interpreted Sl. No. 226 of Notification No. 1/2017-Integrated Tax (Rate) on a plain reading of the words "LED lights or fixtures including LED lamps" and held that "including" is a word of enlargement, not restriction. It rejected the narrower construction that would confine the benefit only to fixtures fitted with or containing LED lamps. On that interpretation, imported lighting fixtures were held eligible for the concessional rate, and the demand, interest and penalty raised on denial of the notification benefit were set aside.
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