Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Customs valuation and classification require comparable evidence and assessment of imported goods in their actual condition, invalidating related pena...
Section 11D was held to operate prospectively because its penal character and plain language indicated application only to amounts collected after its introduction on 20-9-1991. The decisive factor was when the duty-like amounts were collected, not the date of the show-cause notice. The non obstante clause gave the provision overriding effect over inconsistent rules, but did not make it retrospective. Collections made before 20-9-1991 could not be recovered under the section, so the demand was unsustainable.
Section 11D was held to operate prospectively because its penal character and plain language indicated application only to amounts collected after its introduction on 20-9-1991. The decisive factor was when the duty-like amounts were collected, not the date of the show-cause notice. The non obstante clause gave the provision overriding effect over inconsistent rules, but did not make it retrospective. Collections made before 20-9-1991 could not be recovered under the section, so the demand was unsustainable.
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