Prohibited importation of cosmetics without prior regulatory registration attracts seizure and confiscation; warehousing or re export claims do not cu...
Provisional release on security permitted where cash deposit plus bond secures differential duty; classification and treaty benefits referred for deci...
Customs Valuation Rule Sequence must be followed; single-comparator re-determination and penalties set aside without comparability or proof of mis-dec...
Separately Identifiable Services: transportation found to be the essential character, so Cargo Handling classification and extended limitation rejecte...
Clarifies that securitisation trusts constituted under regulatory framework qualify as revocable trusts because the trust deed grants contributors a structured right of revocation and re-transfer of assets, thereby satisfying the re-transfer and re-assumption limbs of revocability; consequence: income is taxable in the hands of Security Receipt Holders, not the trust. Rejects characterization of such trusts as an Association of Persons: the trustee acts under the deed without joint management or common volition, beneficiaries are determinable from records, and therefore AOP assessment and applying general aggregation provisions is inapplicable. Concludes that earlier Tribunal and legislative developments support pass-through taxation of securitisation trusts.
Clarifies that securitisation trusts constituted under regulatory framework qualify as revocable trusts because the trust deed grants contributors a structured right of revocation and re-transfer of assets, thereby satisfying the re-transfer and re-assumption limbs of revocability; consequence: income is taxable in the hands of Security Receipt Holders, not the trust. Rejects characterization of such trusts as an Association of Persons: the trustee acts under the deed without joint management or common volition, beneficiaries are determinable from records, and therefore AOP assessment and applying general aggregation provisions is inapplicable. Concludes that earlier Tribunal and legislative developments support pass-through taxation of securitisation trusts.
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