Business reorganisation requires recognition of successor's modified return; draft orders against dissolved transferor quashed and fresh review direct...
Pre-commencement R&D deduction denied where business had not commenced; deeming benefit requires tangible start of manufacture or commercial exploitat...
Priority of set-off: brought forward business losses must be adjusted before unabsorbed depreciation; procedural safeguards required for invoking rest...
Customs valuation dispute over imported melamine considers whether declared transaction value was inflated to evade anti dumping duty. Tribunal emphasises the transaction value principle (GATT) and requires actual negotiated price evidence rather than reliance on a published price bulletin; consequence: confirmation of ADD based solely on market journal prices and untested electronic or recorded statements is unsustainable. Tribunal also notes electronic evidence and recorded statements require tendering with opportunity for cross examination before an adjudicating authority; absence of corroborative, cogent evidence undermines findings of deliberate overvaluation for ADD evasion.
Customs valuation dispute over imported melamine considers whether declared transaction value was inflated to evade anti dumping duty. Tribunal emphasises the transaction value principle (GATT) and requires actual negotiated price evidence rather than reliance on a published price bulletin; consequence: confirmation of ADD based solely on market journal prices and untested electronic or recorded statements is unsustainable. Tribunal also notes electronic evidence and recorded statements require tendering with opportunity for cross examination before an adjudicating authority; absence of corroborative, cogent evidence undermines findings of deliberate overvaluation for ADD evasion.
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