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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Availability of an alternative statutory appellate remedy ordinarily warrants restraint in exercising writ jurisdiction, but does not create an absolute bar. Customs treatment of adult sex toys as prohibited goods may be challenged where no statutory or notification-based prohibition is identified and the classification is alleged to rest on subjective morality rather than objective law. Such allegations, given their effect on the right to trade, can justify writ scrutiny despite an appellate remedy. The merits of whether the goods are prohibited remain open.
Availability of an alternative statutory appellate remedy ordinarily warrants restraint in exercising writ jurisdiction, but does not create an absolute bar. Customs treatment of adult sex toys as prohibited goods may be challenged where no statutory or notification-based prohibition is identified and the classification is alleged to rest on subjective morality rather than objective law. Such allegations, given their effect on the right to trade, can justify writ scrutiny despite an appellate remedy. The merits of whether the goods are prohibited remain open.
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