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...
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Furnace Oil and Light Diesel Oil require separate commodity classification where technical specifications show material differences in physical characteristics, composition, distillation range, viscosity and end-use. Furnace Oil is a heavier residual fuel oil, while Light Diesel Oil is a middle distillate and cannot be substituted in engines designed for lighter fuel. A specific tariff entry for Light Diesel Oil cannot be extended to Furnace Oil merely because both are used as fuel, absent a common entry. Classification of Furnace Oil as Light Diesel Oil for VAT levy was set aside, requiring fresh assessment on the basis that the products are distinct commodities.
Furnace Oil and Light Diesel Oil require separate commodity classification where technical specifications show material differences in physical characteristics, composition, distillation range, viscosity and end-use. Furnace Oil is a heavier residual fuel oil, while Light Diesel Oil is a middle distillate and cannot be substituted in engines designed for lighter fuel. A specific tariff entry for Light Diesel Oil cannot be extended to Furnace Oil merely because both are used as fuel, absent a common entry. Classification of Furnace Oil as Light Diesel Oil for VAT levy was set aside, requiring fresh assessment on the basis that the products are distinct commodities.
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