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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Foreign Trade Policy transitional arrangements for restricted gold imports may protect bona fide pre-notification transactions even where no irrevocable commercial letter of credit was established. An irrevocable commercial letter of credit secures payment through an independent banking mechanism upon shipping documents, but advance payment exceeding 90% of invoice value may provide the foreign seller with greater security. Mechanical insistence on a letter of credit can defeat the protective purpose of the transitional arrangement where traders and transactions are genuine. Notifications issued as delegated legislation ordinarily operate prospectively unless retrospective operation is statutorily authorised. Transitional benefits were extended to the specified import transactions.
Foreign Trade Policy transitional arrangements for restricted gold imports may protect bona fide pre-notification transactions even where no irrevocable commercial letter of credit was established. An irrevocable commercial letter of credit secures payment through an independent banking mechanism upon shipping documents, but advance payment exceeding 90% of invoice value may provide the foreign seller with greater security. Mechanical insistence on a letter of credit can defeat the protective purpose of the transitional arrangement where traders and transactions are genuine. Notifications issued as delegated legislation ordinarily operate prospectively unless retrospective operation is statutorily authorised. Transitional benefits were extended to the specified import transactions.
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