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...
Imported women's jackets were held to be woven not knitted; therefore classification under Customs Chapter 62 (heading 6202 93 90) is correct and revenue succeeds on classification. The article explains distinguishing woven from knitted garments and rejects the importer's self-declared knitted classification. However, the tribunal found the misclassification arose from erroneous self-assessment rather than fraud, collusion or willful misstatement; consequently extended limitation for duty recovery and penalty liability under the fraud/collusion standard cannot be invoked. Overall outcome: classification upheld for revenue, but penalty and extended-period enforcement were not sustained; appeal partly allowed.
Imported women's jackets were held to be woven not knitted; therefore classification under Customs Chapter 62 (heading 6202 93 90) is correct and revenue succeeds on classification. The article explains distinguishing woven from knitted garments and rejects the importer's self-declared knitted classification. However, the tribunal found the misclassification arose from erroneous self-assessment rather than fraud, collusion or willful misstatement; consequently extended limitation for duty recovery and penalty liability under the fraud/collusion standard cannot be invoked. Overall outcome: classification upheld for revenue, but penalty and extended-period enforcement were not sustained; appeal partly allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4921 
