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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Section 112(a) penalty for an importer's alleged misclassification of removable or exchangeable disc drives was treated as lacking a legal basis where the goods were unavailable at adjudication and no actual confiscation or redemption fine was imposed. The related duty demand and penalties imposed on the importer under the same adjudication order had also been set aside. On these grounds, the Director's penalty for the alleged misclassification was unsustainable and was set aside.
Section 112(a) penalty for an importer's alleged misclassification of removable or exchangeable disc drives was treated as lacking a legal basis where the goods were unavailable at adjudication and no actual confiscation or redemption fine was imposed. The related duty demand and penalties imposed on the importer under the same adjudication order had also been set aside. On these grounds, the Director's penalty for the alleged misclassification was unsustainable and was set aside.
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