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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End-use based customs duty concession for imported lithium-ion cells applies only where the specified manufacture results in a new product with a distinct nature, character, use or name. Cells damaged, rejected or scrapped during battery or battery-pack assembly or testing, and subsequently sold as scrap, do not satisfy that end-use. In the absence of a separate allowance for process loss or wastage, they are treated as unutilised or defective goods under the IGCR Rules. The concession must therefore be reversed through payment of the differential duty otherwise payable at import, with applicable interest. Duty is calculated on the quantity and value assessed at import, without regard to the scrap sale value.
End-use based customs duty concession for imported lithium-ion cells applies only where the specified manufacture results in a new product with a distinct nature, character, use or name. Cells damaged, rejected or scrapped during battery or battery-pack assembly or testing, and subsequently sold as scrap, do not satisfy that end-use. In the absence of a separate allowance for process loss or wastage, they are treated as unutilised or defective goods under the IGCR Rules. The concession must therefore be reversed through payment of the differential duty otherwise payable at import, with applicable interest. Duty is calculated on the quantity and value assessed at import, without regard to the scrap sale value.
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