Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Maintainability of advance ruling application questioned due to pending classification issue before Customs Officer for 13 imported products used in Lithium-ion cell manufacturing. Advance ruling definition u/s 28E allows rulings on pre-importation questions, but Customs Authorities have issued rulings on post-importation queries for consistency and facilitation. Section 28 provides for pre-notice consultation and duty payment by importer before notice for short-levy. Applicant initiated reassessment process, rendering advance ruling application liable for rejection as classification issue pending before Customs Officer. Advance ruling application dismissed.
Maintainability of advance ruling application questioned due to pending classification issue before Customs Officer for 13 imported products used in Lithium-ion cell manufacturing. Advance ruling definition u/s 28E allows rulings on pre-importation questions, but Customs Authorities have issued rulings on post-importation queries for consistency and facilitation. Section 28 provides for pre-notice consultation and duty payment by importer before notice for short-levy. Applicant initiated reassessment process, rendering advance ruling application liable for rejection as classification issue pending before Customs Officer. Advance ruling application dismissed.
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