Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
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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TaxTMI 
TaxTMI 
of 4886 
