Concessional corporate tax option under section 115BAA survives procedural documentary lapses when statutory compliance and earlier exercise are estab...
Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Seizure of imported bulk liquid cargo as "Distillate Oil" was challenged on the ground that classification based on cloud point and alleged similarity to automotive diesel was uncertain. The court held that cloud point is not a definitive determinant because operability varies by vessel, climate, and end use, and similarly situated cargo with a higher (less stringent) cloud point had been released, making differential treatment unjustified; consequently, seizure could not rest on that parameter and was unsustainable. It further held that overlapping "diesel fraction" characteristics and ambiguous expert opinions/lab results could not establish that the cargo was automotive diesel, and in such ambiguity classification cannot be inferred merely on probability; therefore, the seizure memo was quashed and release directed. - HC
Seizure of imported bulk liquid cargo as "Distillate Oil" was challenged on the ground that classification based on cloud point and alleged similarity to automotive diesel was uncertain. The court held that cloud point is not a definitive determinant because operability varies by vessel, climate, and end use, and similarly situated cargo with a higher (less stringent) cloud point had been released, making differential treatment unjustified; consequently, seizure could not rest on that parameter and was unsustainable. It further held that overlapping "diesel fraction" characteristics and ambiguous expert opinions/lab results could not establish that the cargo was automotive diesel, and in such ambiguity classification cannot be inferred merely on probability; therefore, the seizure memo was quashed and release directed. - HC
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