Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
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CESTAT held that imported Mixed Hydrocarbon Oil was correctly classified under CTI 27011990, not as Automotive Diesel Fuel under CTI 27101944. CRCL laboratory testing confirmed the product did not meet IS:1460:2005 standards for automotive diesel. The tribunal emphasized that classification burden lies with Revenue per SC precedent in H.P.L. Chemicals. Appellant's admission under investigation cannot alone determine classification without corroborating evidence. Department failed to substantiate misclassification allegations with legally admissible evidence. The appeal was allowed, setting aside the original classification order, confirming goods as Mixed Hydrocarbon Oil under CTI 27011990.
CESTAT held that imported Mixed Hydrocarbon Oil was correctly classified under CTI 27011990, not as Automotive Diesel Fuel under CTI 27101944. CRCL laboratory testing confirmed the product did not meet IS:1460:2005 standards for automotive diesel. The tribunal emphasized that classification burden lies with Revenue per SC precedent in H.P.L. Chemicals. Appellant's admission under investigation cannot alone determine classification without corroborating evidence. Department failed to substantiate misclassification allegations with legally admissible evidence. The appeal was allowed, setting aside the original classification order, confirming goods as Mixed Hydrocarbon Oil under CTI 27011990.
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