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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Customs-duty liability arising from confiscation and redemption is distinct from the original Bill of Entry assessment. Statutory interest, where payable, cannot accrue before that consequential liability is determined in confiscation proceedings, although departmental delay does not by itself eliminate interest. Interest charged from the original assessment until adjudication was therefore unsustainable and requires recomputation from determination of liability, subject to reassessment and payments or appropriations. Limited writ review may remain available despite an appellate remedy where undisputed facts raise only the legal question of the period for consequential-interest computation and do not challenge classification, confiscation, redemption fine, or penalties.
Customs-duty liability arising from confiscation and redemption is distinct from the original Bill of Entry assessment. Statutory interest, where payable, cannot accrue before that consequential liability is determined in confiscation proceedings, although departmental delay does not by itself eliminate interest. Interest charged from the original assessment until adjudication was therefore unsustainable and requires recomputation from determination of liability, subject to reassessment and payments or appropriations. Limited writ review may remain available despite an appellate remedy where undisputed facts raise only the legal question of the period for consequential-interest computation and do not challenge classification, confiscation, redemption fine, or penalties.
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