Charitable sports promotion: sponsorship receipts alone did not defeat registration where funds supported tournaments and player development activitie...
Overdue associated-enterprise receivables: debt-free status defeated notional-interest adjustment, while employee stock-option costs qualified as busi...
Retrospective assessment-limitation amendments validate final orders while contemporaneous segment data governs transfer-pricing comparability and tol...
Transfer pricing adjustments must track international transactions, while unsupported AMP adjustments and unsuitable manufacturing comparables require...
Transfer-pricing adjustments must reflect functional comparability, working-capital effects, and avoid duplicating interest on associated-enterprise r...
Technical expert opinion in customs classification and exemption disputes must be meaningfully evaluated where eligibility depends on physical inspection and component-level analysis. An adjudicating authority cannot reject such opinion through its own technical perception without a reasoned technical rebuttal supported by comparable expert or scientific material. The order denying concessional customs duty for Battery Management Systems and Cell Supervisory Circuits was quashed and remanded for fresh adjudication, with liberty to obtain a counter-expert opinion. Writ jurisdiction was exercised despite an alternative appellate remedy because the specialised technical opinion had been disregarded without a reasoned technical basis.
Technical expert opinion in customs classification and exemption disputes must be meaningfully evaluated where eligibility depends on physical inspection and component-level analysis. An adjudicating authority cannot reject such opinion through its own technical perception without a reasoned technical rebuttal supported by comparable expert or scientific material. The order denying concessional customs duty for Battery Management Systems and Cell Supervisory Circuits was quashed and remanded for fresh adjudication, with liberty to obtain a counter-expert opinion. Writ jurisdiction was exercised despite an alternative appellate remedy because the specialised technical opinion had been disregarded without a reasoned technical basis.
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