Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Turnover mismatches under percentage-completion accounting cannot alone establish suppressed income where customer advances remain recorded as liabili...
Rule 12 permits rejection of declared customs value only where there is reason to doubt its truth or accuracy, the importer has an opportunity to explain the price, and valuation follows the prescribed method, including contemporaneous import values where relevant. Unsupported intelligence and recovered documents did not establish undervaluation, rendering redetermination and differential duty unsustainable. Electronic data, messages, emails and invoices required statutory certification and reliable authentication; unauthenticated material could not prove undervaluation. Each IEC holder filing its own bill of entry remained the importer liable for duty, preventing recovery from an alleged proxy importer. Goods unavailable for confiscation could not attract confiscation or redemption fine.
Rule 12 permits rejection of declared customs value only where there is reason to doubt its truth or accuracy, the importer has an opportunity to explain the price, and valuation follows the prescribed method, including contemporaneous import values where relevant. Unsupported intelligence and recovered documents did not establish undervaluation, rendering redetermination and differential duty unsustainable. Electronic data, messages, emails and invoices required statutory certification and reliable authentication; unauthenticated material could not prove undervaluation. Each IEC holder filing its own bill of entry remained the importer liable for duty, preventing recovery from an alleged proxy importer. Goods unavailable for confiscation could not attract confiscation or redemption fine.
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