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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Rice bran oil and de-oiled rice bran produced through technical extraction and refining are manufactured commodities, not processed agricultural produce. The Schedule cannot expand the statutory definition of agricultural produce; executive inclusion of those products, consequential market-fee demands, and associated orders were invalid, with refund of paid fees directed. Market-fee amendments did not directly or immediately restrict movement of goods under Article 301 and did not require prior Presidential sanction. The special deemed-sale definition validly prevents fee evasion and is compatible with the Sale of Goods Act. Availability of market-wide regulatory services, rather than actual individual use, supports a fee levy on covered produce. Industrial and agricultural-market regulation operate in distinct fields, so no repugnancy arises.
Rice bran oil and de-oiled rice bran produced through technical extraction and refining are manufactured commodities, not processed agricultural produce. The Schedule cannot expand the statutory definition of agricultural produce; executive inclusion of those products, consequential market-fee demands, and associated orders were invalid, with refund of paid fees directed. Market-fee amendments did not directly or immediately restrict movement of goods under Article 301 and did not require prior Presidential sanction. The special deemed-sale definition validly prevents fee evasion and is compatible with the Sale of Goods Act. Availability of market-wide regulatory services, rather than actual individual use, supports a fee levy on covered produce. Industrial and agricultural-market regulation operate in distinct fields, so no repugnancy arises.
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