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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DGFT interpretation of the Foreign Trade Policy is final and binding on Customs, including whether entities qualify as group companies. Common directorial voting control meeting the prescribed threshold permits use of a group company's duty credit scrips and service-export earnings towards an importer's EPCG export obligation. Capital goods for service-sector exemptions include equipment and accessories required directly or indirectly to render services; helicopter parts used for operational transport supporting remote infrastructure projects may qualify on that basis. Aviation permission describing private use does not by itself establish personal use. Extended limitation requires deliberate non-disclosure intended to evade duty, and prior departmental knowledge negates wilful suppression.
DGFT interpretation of the Foreign Trade Policy is final and binding on Customs, including whether entities qualify as group companies. Common directorial voting control meeting the prescribed threshold permits use of a group company's duty credit scrips and service-export earnings towards an importer's EPCG export obligation. Capital goods for service-sector exemptions include equipment and accessories required directly or indirectly to render services; helicopter parts used for operational transport supporting remote infrastructure projects may qualify on that basis. Aviation permission describing private use does not by itself establish personal use. Extended limitation requires deliberate non-disclosure intended to evade duty, and prior departmental knowledge negates wilful suppression.
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