Electronic WhatsApp evidence without authentication or independent corroboration cannot sustain an unexplained-investment addition based on third-part...
Mutual current-account transactions excluded from deemed dividend treatment where no fresh borrowing arose; unsupported unsecured-loan addition also f...
Deeming provision in Chapter Note 4 to Chapter 26 treats conversion of ores into concentrates as manufacture; where pre shipment processes (washing, crushing, screening, sizing) materially remove impurities or upgrade material, the resultant product is a concentrate and falls outside the exemption under Notification No.04/2006 CE, and the imported consignments so processed were held to be concentrates and ineligible for exemption. Beneficiation and strict construction of exemption notifications place the onus on the importer to prove eligibility. Statutory provisions require payment of interest on duty once a demand is confirmed, and appellants remain liable for duty and interest.
Deeming provision in Chapter Note 4 to Chapter 26 treats conversion of ores into concentrates as manufacture; where pre shipment processes (washing, crushing, screening, sizing) materially remove impurities or upgrade material, the resultant product is a concentrate and falls outside the exemption under Notification No.04/2006 CE, and the imported consignments so processed were held to be concentrates and ineligible for exemption. Beneficiation and strict construction of exemption notifications place the onus on the importer to prove eligibility. Statutory provisions require payment of interest on duty once a demand is confirmed, and appellants remain liable for duty and interest.
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