Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
Whether customs duty on conversion from foreign to coastal run is leviable when import occurred before Notification No.12/2012: court held liability arises at the time of first import (date of import controls), and because the relevant imports predated the Notification, no duty was attractable - demand quashed. Whether the impugned letter constituted a valid demand or merely a show-cause notice: court found the enclosed computation and 14-day remittance call rendered it a substantive demand, not a procedural notice, and therefore the communication was invalid - quashed. - HC
Whether customs duty on conversion from foreign to coastal run is leviable when import occurred before Notification No.12/2012: court held liability arises at the time of first import (date of import controls), and because the relevant imports predated the Notification, no duty was attractable - demand quashed. Whether the impugned letter constituted a valid demand or merely a show-cause notice: court found the enclosed computation and 14-day remittance call rendered it a substantive demand, not a procedural notice, and therefore the communication was invalid - quashed. - HC
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