Income-tax prosecution fails when appellate remand removes its factual foundation; directors require company arraignment for vicarious criminal liabil...
Capital character of assignment consideration prevents taxation as residuary income, while unsupported interest-related expenditure remains non-deduct...
Make-available condition shields regional support-service receipts from Indian taxation where no independent capability or permanent establishment exi...
Transfer-pricing treatment of corporate guarantees and convertible loans followed prior-year consistency, with taxable foreign dividends excluded from...
Transfer-pricing benchmarking confines adjustments to associated-enterprise transactions and integrates delayed receivables through TNMM working-capit...
Medical relief status protects government-contracted mobile healthcare from commercial classification, while provisional registration cancellation req...
Charitable registration cancellation requires proof that educational activities abandoned their objects; incidental receipts and retained surplus are ...
Burden of proof for reclassification rests on Revenue where imported lead-bearing powder is proposed to be classified as lead waste and scrap rather than declared lead concentrate. Conflicting scientific reports that identify principally lead oxide and lead sulphate, with only negligible metallic lead, do not conclusively establish classification under tariff item 78020090. Heading 7802 concerns lead in metallic or primary form, while lead oxide and lead sulphate fall separately within Chapter 28. Technical literature and import-export descriptions cannot displace the declared classification without reliable scientific proof of the goods' identity.
Burden of proof for reclassification rests on Revenue where imported lead-bearing powder is proposed to be classified as lead waste and scrap rather than declared lead concentrate. Conflicting scientific reports that identify principally lead oxide and lead sulphate, with only negligible metallic lead, do not conclusively establish classification under tariff item 78020090. Heading 7802 concerns lead in metallic or primary form, while lead oxide and lead sulphate fall separately within Chapter 28. Technical literature and import-export descriptions cannot displace the declared classification without reliable scientific proof of the goods' identity.
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