Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Naphtha procured under exemption notifications for use in the manufacture of fertilizer or ammonia qualified for concessional or nil duty when the goods were intended for that use, even if a portion of the input was diverted to electricity generation that also supported the fertiliser plant. The Court held that the notifications required proof of intended use, not exclusive actual end-use in every downstream stage, so the duty demand on alleged non-eligible use failed. On limitation, extended period invocation required deliberate suppression, fraud, collusion, wilful misstatement, or contravention with intent to evade duty; those elements were absent, the matter was interpretational, and the dispute was revenue neutral. The demand and penalty were therefore time-barred.
Naphtha procured under exemption notifications for use in the manufacture of fertilizer or ammonia qualified for concessional or nil duty when the goods were intended for that use, even if a portion of the input was diverted to electricity generation that also supported the fertiliser plant. The Court held that the notifications required proof of intended use, not exclusive actual end-use in every downstream stage, so the duty demand on alleged non-eligible use failed. On limitation, extended period invocation required deliberate suppression, fraud, collusion, wilful misstatement, or contravention with intent to evade duty; those elements were absent, the matter was interpretational, and the dispute was revenue neutral. The demand and penalty were therefore time-barred.
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