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...
The article addresses whether an additional levy in the nature of a surcharge is payable over the tax on taxable turnover of declared goods: it explains that the tax on declared goods is prescribed at a concessional rate for sales against the prescribed declaration and that Section 7 confines the rate and mode of that levy; however a separate provision commencing with a non-obstante clause imposes an additional tax calculated on the tax payable, so the surcharge is a distinct levy with its own taxable event, person, rate and measure and is therefore leviable in addition to the tax, subject to the statutory aggregate ceiling aligning with central law.
The article addresses whether an additional levy in the nature of a surcharge is payable over the tax on taxable turnover of declared goods: it explains that the tax on declared goods is prescribed at a concessional rate for sales against the prescribed declaration and that Section 7 confines the rate and mode of that levy; however a separate provision commencing with a non-obstante clause imposes an additional tax calculated on the tax payable, so the surcharge is a distinct levy with its own taxable event, person, rate and measure and is therefore leviable in addition to the tax, subject to the statutory aggregate ceiling aligning with central law.
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