Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Natural justice in insolvency-professional discipline requires disclosed material; notices based on extraneous material and ignored defences are vitia...
Customs reclassification of mixed-fibre polyester warp knitted fabrics requires Revenue to establish, through cogent technical evidence, that the declared residual classification is incorrect. Fibre composition and textile construction under Chapter 60 cannot be determined solely from commercial documents, visual examination, or a generic polyester description. Where samples, laboratory reports, and evidence of misdeclaration or suppression are absent, an accepted self-assessment cannot be reopened or replaced with multiple alternative tariff entries. Classification under Customs Tariff Item 6005 9000 and the related concessional basic customs duty benefit therefore remained available, and the differential duty, interest, and penalties were unsustainable.
Customs reclassification of mixed-fibre polyester warp knitted fabrics requires Revenue to establish, through cogent technical evidence, that the declared residual classification is incorrect. Fibre composition and textile construction under Chapter 60 cannot be determined solely from commercial documents, visual examination, or a generic polyester description. Where samples, laboratory reports, and evidence of misdeclaration or suppression are absent, an accepted self-assessment cannot be reopened or replaced with multiple alternative tariff entries. Classification under Customs Tariff Item 6005 9000 and the related concessional basic customs duty benefit therefore remained available, and the differential duty, interest, and penalties were unsustainable.
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