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...
A ministerial certificate authorising import of a specified stainless steel grade is binding on other importers; where the Ministry has permitted import of that grade for one party, the same permission applies to others and precludes sustaining import restrictions. Customs identification of the consignment by the declared grade is dispositive for classification. Applying that ratio, the commentary concludes that challenges to redemption fine and personal penalty succeed where they rested solely on disallowing import of the certified grade, entitling affected importers to relief on those penalty aspects.
A ministerial certificate authorising import of a specified stainless steel grade is binding on other importers; where the Ministry has permitted import of that grade for one party, the same permission applies to others and precludes sustaining import restrictions. Customs identification of the consignment by the declared grade is dispositive for classification. Applying that ratio, the commentary concludes that challenges to redemption fine and personal penalty succeed where they rested solely on disallowing import of the certified grade, entitling affected importers to relief on those penalty aspects.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
