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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Greenhouses cleared from the factory in ready-to-assemble condition fall under the specific tariff entry for greenhouses in ready-to-assemble sets rather than the general entry for plant growth chambers, applying Rule 3(a)'s preference for the most specific description. An amendment extending the normal excise-demand limitation period from one year to two years operates prospectively absent express retrospective effect and cannot revive a demand already time-barred. On that limitation basis, the duty demand, interest and penalty were set aside.
Greenhouses cleared from the factory in ready-to-assemble condition fall under the specific tariff entry for greenhouses in ready-to-assemble sets rather than the general entry for plant growth chambers, applying Rule 3(a)'s preference for the most specific description. An amendment extending the normal excise-demand limitation period from one year to two years operates prospectively absent express retrospective effect and cannot revive a demand already time-barred. On that limitation basis, the duty demand, interest and penalty were set aside.
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