International transaction characterisation of domestic divestment of support services business rejected; transaction between resident associated enter...
Minimum Import Price restrictions for Black Pepper, Areca-nuts and Apples upheld; procedural laying failure not fatal, notifications to be placed befo...
Transaction value between related persons requires market-equivalent pricing; importer must prove declared value mirrors ordinary international trade ...
Classification of exported insecticides under export tariff affirmed; reclassification and related penalties set aside and MEIS scrip jurisdiction rec...
Reopening of assessment under the new regime requires supplying to the taxpayer the materials forming the basis for reopening; where only a notice and reasons recorded were provided without annexed material, the taxpayer was deprived of an effective opportunity to respond and the subsequent order under the new procedure was invalidated. The note emphasises that failure to furnish underlying information precludes meaningful representation and renders the reopening notice defective, aligning with higher-court guidance that materials must be disclosed before final action is taken.
Reopening of assessment under the new regime requires supplying to the taxpayer the materials forming the basis for reopening; where only a notice and reasons recorded were provided without annexed material, the taxpayer was deprived of an effective opportunity to respond and the subsequent order under the new procedure was invalidated. The note emphasises that failure to furnish underlying information precludes meaningful representation and renders the reopening notice defective, aligning with higher-court guidance that materials must be disclosed before final action is taken.
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