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...
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.
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