Third-party loose sheets require reliable nexus before supporting unexplained expenditure additions; presumptions do not establish payer identity or o...
TNMM comparability using audited accounts and working-capital adjustments can eliminate unwarranted transfer-pricing additions where verified margins ...
Gross-profit additions on disputed purchases require reasoned appellate determination; disclosed claims alone do not support inaccurate-particulars pe...
Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barr...
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursement...
Palmolein classification defeated the crude-oil concession; material misdeclaration sustained recovery and confiscation, while separate false-document...
Liability to pay customs duty when confiscated goods are redeemed after payment of fine u/s 125 of the Customs Act, 1962 includes liability to pay interest on delayed payment u/s 28AB. The customs duty obligation arises only after exercising the option to redeem confiscated goods u/s 125. Once exercised, acceptance is subject to conditions specified, primarily payment of fine in lieu of confiscation. This duty obligation is inextricably connected to the redemption option and is a precondition. The duty obligation does not occasion u/ss 12 or 28 but arises due to the option exercised u/s 125. Section 28 applies for assessing and determining the duty payable u/s 125(2). Once Section 28 applies, interest on delayed payment arises u/s 28AB, obligating payment of interest in addition to duty. The Jagdish Cancer case is not an authority against applying Section 28 for duty calculation when liability arises u/s 125.
Liability to pay customs duty when confiscated goods are redeemed after payment of fine u/s 125 of the Customs Act, 1962 includes liability to pay interest on delayed payment u/s 28AB. The customs duty obligation arises only after exercising the option to redeem confiscated goods u/s 125. Once exercised, acceptance is subject to conditions specified, primarily payment of fine in lieu of confiscation. This duty obligation is inextricably connected to the redemption option and is a precondition. The duty obligation does not occasion u/ss 12 or 28 but arises due to the option exercised u/s 125. Section 28 applies for assessing and determining the duty payable u/s 125(2). Once Section 28 applies, interest on delayed payment arises u/s 28AB, obligating payment of interest in addition to duty. The Jagdish Cancer case is not an authority against applying Section 28 for duty calculation when liability arises u/s 125.
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TaxTMI 
TaxTMI 
of 4891 
