Toy balloon tariff classification: functional heading prevails over residual rubber and festive article headings, supporting penalties for deliberate ...
Customs valuation using comparable contemporaneous imports can displace declared value, while missing speaking orders require pursuit before competent...
Foreign customs declarations and importer admissions established undervaluation, supporting sequential value redetermination, differential duty, and m...
Customs seizure safeguards prevent detention-based limitation avoidance and invalidate provisional release conditions for imported vehicles under an i...
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Revision under section 263 must be initiated within two years from the end of the financial year in which the assessment order was passed. The limitation expired before the first revisionary notice and order were issued, rendering the revisionary order time-barred and liable to be quashed. Independently, revision of the assessment treating integrated hardware systems with embedded software as non-royalty was unwarranted because the Assessing Officer had examined the agreements, copyright rights, software and services, and the India-United Kingdom tax treaty. Consistent earlier decisions and the Supreme Court's Engineering Analysis ruling supported the non-royalty treatment, so the assessment order was not erroneous or prejudicial to Revenue interests.
Revision under section 263 must be initiated within two years from the end of the financial year in which the assessment order was passed. The limitation expired before the first revisionary notice and order were issued, rendering the revisionary order time-barred and liable to be quashed. Independently, revision of the assessment treating integrated hardware systems with embedded software as non-royalty was unwarranted because the Assessing Officer had examined the agreements, copyright rights, software and services, and the India-United Kingdom tax treaty. Consistent earlier decisions and the Supreme Court's Engineering Analysis ruling supported the non-royalty treatment, so the assessment order was not erroneous or prejudicial to Revenue interests.
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