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...
Extended limitation for customs duty under Section 28(4) requires material showing collusion, wilful misstatement or suppression causing short-payment; a subsequent departmental view on classification or exemption is insufficient. Disclosure of the goods description, classification and exemption claim in the Bill of Entry, accepted by the proper officer, did not establish concealment, false declaration or deliberate suppression to evade differential IGST on imported rice bran. The demand was therefore set aside without determining the correct classification or IGST liability, while preserving timely action permitted by law. Writ jurisdiction remains available despite a statutory appeal where extended-period jurisdictional conditions are unmet.
Extended limitation for customs duty under Section 28(4) requires material showing collusion, wilful misstatement or suppression causing short-payment; a subsequent departmental view on classification or exemption is insufficient. Disclosure of the goods description, classification and exemption claim in the Bill of Entry, accepted by the proper officer, did not establish concealment, false declaration or deliberate suppression to evade differential IGST on imported rice bran. The demand was therefore set aside without determining the correct classification or IGST liability, while preserving timely action permitted by law. Writ jurisdiction remains available despite a statutory appeal where extended-period jurisdictional conditions are unmet.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
