SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
Revenue must establish tariff reclassification through evidence of each imported article's objective characteristics, applicable tariff entries, Section Notes and Explanatory Notes; representative sampling, undisclosed website material and unreasoned end-use assertions were insufficient. The proposed reclassification and consequential denial of concessional duty failed. Extended limitation required pleaded and proven collusion, wilful misstatement or suppression; a corrigendum could not add new articles or bills of entry, and charges first introduced through it ran from its date. The extended-period demand was unavailable. Duty determination had to reconcile annexures and appropriate verified payments, so the unreconciled demand failed. Incorrect tariff classification without false description or exemption breach did not justify confiscation, redemption fine, penalty or consequential interest; these were set aside, subject to any timely verified residual short-payment determination.
Revenue must establish tariff reclassification through evidence of each imported article's objective characteristics, applicable tariff entries, Section Notes and Explanatory Notes; representative sampling, undisclosed website material and unreasoned end-use assertions were insufficient. The proposed reclassification and consequential denial of concessional duty failed. Extended limitation required pleaded and proven collusion, wilful misstatement or suppression; a corrigendum could not add new articles or bills of entry, and charges first introduced through it ran from its date. The extended-period demand was unavailable. Duty determination had to reconcile annexures and appropriate verified payments, so the unreconciled demand failed. Incorrect tariff classification without false description or exemption breach did not justify confiscation, redemption fine, penalty or consequential interest; these were set aside, subject to any timely verified residual short-payment determination.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
