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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...
Interpretation of an exemption notification for imported crude palm oil focused on acid value as the sole contested parameter. The tribunal applied a strict textual interpretation, holding that the phrase "acid value 4 or more" contains no upper limit, so no higher acid-value cutoff may be read into the notification; consequence: notification benefit cannot be denied on that ground. The tribunal further treated reprocessing and PHO clearance as operative compliance evidence, nullifying claims that the goods failed edible-grade standards and resulting in allowance of the appeals with consequential relief.
Interpretation of an exemption notification for imported crude palm oil focused on acid value as the sole contested parameter. The tribunal applied a strict textual interpretation, holding that the phrase "acid value 4 or more" contains no upper limit, so no higher acid-value cutoff may be read into the notification; consequence: notification benefit cannot be denied on that ground. The tribunal further treated reprocessing and PHO clearance as operative compliance evidence, nullifying claims that the goods failed edible-grade standards and resulting in allowance of the appeals with consequential relief.
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