Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
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Advance ruling was barred for roasted areca nuts because their classification had already been upheld by the High Court and no new facts were presented; the application was therefore disallowed without a merits ruling. Roasted walnuts subjected to severe heat treatment were distinguished from dried nuts, as roasting materially changes moisture, colour, appearance and flavour. Because Chapter 8 does not contemplate roasting, the walnuts fall under Heading 2008 and are classified as other roasted nuts and seeds under CTI 2008 19 91. Preferential customs duty is available only where the importer proves origin to the competent customs officer under the applicable origin rules and the Customs (Administration of Rules of Origin under Trade Agreements) Rules, 2020.
Advance ruling was barred for roasted areca nuts because their classification had already been upheld by the High Court and no new facts were presented; the application was therefore disallowed without a merits ruling. Roasted walnuts subjected to severe heat treatment were distinguished from dried nuts, as roasting materially changes moisture, colour, appearance and flavour. Because Chapter 8 does not contemplate roasting, the walnuts fall under Heading 2008 and are classified as other roasted nuts and seeds under CTI 2008 19 91. Preferential customs duty is available only where the importer proves origin to the competent customs officer under the applicable origin rules and the Customs (Administration of Rules of Origin under Trade Agreements) Rules, 2020.
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