Jurisdictional sanction requirements bar reassessment when approval comes from an authority lacking statutory competence under the applicable framewor...
Recorded sales receipts cannot be reassessed as unexplained cash credits, eliminating the basis for consequential alleged commission expenditure addit...
Sufficient cause for delayed income-tax appeals requires bona fide diligence; unsubstantiated counsel illness and assessee inaction defeat condonation...
TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
Internal TNMM supports deletion of freight-forwarding adjustments where comparable non-AE transactions are separately identifiable and materially simi...
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Rectification or modification of an advance ruling cannot reopen its merits or waive an express condition of a customs exemption. Exemption for imported goods repaired or refurbished and re-exported remains subject to Notification No. 134/94-Cus, including performance of prescribed operations under Section 65 of the Customs Act, 1962. A DTA unit's operational difficulty in not operating under the MOOWR scheme does not constitute a mistake apparent from the record or a legal or factual error. Alternative safeguards, conditions under other notifications, and proposed traceability measures cannot replace the governing notification's express requirement. The request to dispense with that condition was rejected, leaving the ruling operative subject to all notification conditions.
Rectification or modification of an advance ruling cannot reopen its merits or waive an express condition of a customs exemption. Exemption for imported goods repaired or refurbished and re-exported remains subject to Notification No. 134/94-Cus, including performance of prescribed operations under Section 65 of the Customs Act, 1962. A DTA unit's operational difficulty in not operating under the MOOWR scheme does not constitute a mistake apparent from the record or a legal or factual error. Alternative safeguards, conditions under other notifications, and proposed traceability measures cannot replace the governing notification's express requirement. The request to dispense with that condition was rejected, leaving the ruling operative subject to all notification conditions.
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