Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
Imported consignments declared as industrial oil were held classifiable as Automotive Diesel Fuel/High-Speed Diesel under the 'most akin' test because combined laboratory reports unambiguously showed the samples comprised diesel fraction adulterated with lighter hydrocarbons and matched multiple HFHSD/ADF parameters; the product was therefore a restricted import. The court found cumulative CRCL and MRPL reports valid and sufficient since together they covered the prescribed Indian Standard parameters, sampling was undisputed, and substance of reports was not challenged. Testing in multiple accredited laboratories was permitted where one lab cannot cover all prescribed parameters and combined results satisfy the required tests.
Imported consignments declared as industrial oil were held classifiable as Automotive Diesel Fuel/High-Speed Diesel under the 'most akin' test because combined laboratory reports unambiguously showed the samples comprised diesel fraction adulterated with lighter hydrocarbons and matched multiple HFHSD/ADF parameters; the product was therefore a restricted import. The court found cumulative CRCL and MRPL reports valid and sufficient since together they covered the prescribed Indian Standard parameters, sampling was undisputed, and substance of reports was not challenged. Testing in multiple accredited laboratories was permitted where one lab cannot cover all prescribed parameters and combined results satisfy the required tests.
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