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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Approval of a resolution plan settling confirmed government dues causes the corporate debtor's pending excise appeal to abate. Excise duty remains payable by persons who clear processed fabrics, even where they are not manufacturers, because liability attaches on clearance; however, the transferee's specific penalty concerning stock was not sustained. Pre-clearance grading, cartage, brokerage and stock-interest expenses form part of assessable value where goods enter wholesale trade only on sale to independent buyers, sustaining the related duty and interest. Penalty for intent to evade duty requires findings of prescribed conduct and cannot rest solely on inadmissible valuation deductions. Penalties relating to confiscable goods likewise require their statutory basis; general penalties may instead apply to proven participation in duty evasion.
Approval of a resolution plan settling confirmed government dues causes the corporate debtor's pending excise appeal to abate. Excise duty remains payable by persons who clear processed fabrics, even where they are not manufacturers, because liability attaches on clearance; however, the transferee's specific penalty concerning stock was not sustained. Pre-clearance grading, cartage, brokerage and stock-interest expenses form part of assessable value where goods enter wholesale trade only on sale to independent buyers, sustaining the related duty and interest. Penalty for intent to evade duty requires findings of prescribed conduct and cannot rest solely on inadmissible valuation deductions. Penalties relating to confiscable goods likewise require their statutory basis; general penalties may instead apply to proven participation in duty evasion.
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