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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Customs valuation safeguards require the proper officer to communicate written reasons for doubting a declared transaction value and disclose relevant contemporaneous import particulars, including quantity, quality and temporal comparability. Acceptance letters given while seeking clearance on payment of duty under protest do not by themselves establish voluntary acceptance of enhanced value or waive these requirements. Written acceptance of reassessment may dispense with a speaking order, but it does not extinguish the statutory right to challenge reassessment on merits. Consent or acquiescence cannot defeat a statutory appeal; enhancement founded solely on undisclosed comparable data and acceptance letters cannot be sustained, and rejection of such appeals must be set aside with consequential relief.
Customs valuation safeguards require the proper officer to communicate written reasons for doubting a declared transaction value and disclose relevant contemporaneous import particulars, including quantity, quality and temporal comparability. Acceptance letters given while seeking clearance on payment of duty under protest do not by themselves establish voluntary acceptance of enhanced value or waive these requirements. Written acceptance of reassessment may dispense with a speaking order, but it does not extinguish the statutory right to challenge reassessment on merits. Consent or acquiescence cannot defeat a statutory appeal; enhancement founded solely on undisclosed comparable data and acceptance letters cannot be sustained, and rejection of such appeals must be set aside with consequential relief.
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