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...
Imported aluminium tubes, pipes and profiles were held to be raw aluminium inputs classifiable under specific tariff headings rather than as motor vehicle parts; specific tariff entries prevail over generic Heading 8708, so the goods are not solely or principally for motor vehicle use and qualify for the exemption notifications, the effect being grant of exemption. Country-of-origin documentation satisfied origin requirements, so exemption applies. Misclassification was treated as interpretation, not misrepresentation, precluding invocation of extended limitation; consequentially interest and penalties and confiscation proposals were rejected.
Imported aluminium tubes, pipes and profiles were held to be raw aluminium inputs classifiable under specific tariff headings rather than as motor vehicle parts; specific tariff entries prevail over generic Heading 8708, so the goods are not solely or principally for motor vehicle use and qualify for the exemption notifications, the effect being grant of exemption. Country-of-origin documentation satisfied origin requirements, so exemption applies. Misclassification was treated as interpretation, not misrepresentation, precluding invocation of extended limitation; consequentially interest and penalties and confiscation proposals were rejected.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
