Constitutional personal-liberty safeguards limit PMLA twin bail conditions where completed investigations lead to prolonged incarceration before trial...
Automated airline software subscriptions without human intervention fail technical-services characterisation and do not make available underlying tech...
Business support recruitment and training receipts qualify for presumptive business taxation, not professional taxation under technical consultancy ru...
Treaty exemption for foreign permanent-establishment management fees prevailed, while dividend expense disallowance remained limited to an accepted al...
Centralised assessment transfers: participation after requesting centralisation can bar technical jurisdictional challenges, while assessment disputes...
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Written acceptance of customs reassessment under Section 17(5) may dispense with a speaking order but does not, by itself, waive an importer's statutory right to challenge enhanced valuation. Consent letters must be read with the surrounding correspondence; payment under protest or requests for provisional clearance may negate unconditional acceptance. Transaction value remains the primary basis for valuation. Declared value may be rejected only where objectively grounded reasonable doubt exists under Rule 12, with written disclosure of grounds and a hearing on request. Any redetermination must follow the sequential valuation rules and rely on demonstrably comparable import data; generic NIDB references are insufficient. Challenges to an unchanged assessment must proceed through the statutory appeal route, not refund proceedings.
Written acceptance of customs reassessment under Section 17(5) may dispense with a speaking order but does not, by itself, waive an importer's statutory right to challenge enhanced valuation. Consent letters must be read with the surrounding correspondence; payment under protest or requests for provisional clearance may negate unconditional acceptance. Transaction value remains the primary basis for valuation. Declared value may be rejected only where objectively grounded reasonable doubt exists under Rule 12, with written disclosure of grounds and a hearing on request. Any redetermination must follow the sequential valuation rules and rely on demonstrably comparable import data; generic NIDB references are insufficient. Challenges to an unchanged assessment must proceed through the statutory appeal route, not refund proceedings.
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