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...
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Where imported goods are supported by Certificates of Origin issued by the designated authority of the exporting country, any reasonable doubt about authenticity or origin particulars must be addressed through the retroactive verification mechanism under Rule 15 of Annexure B to the Interim Rules of Origin. If the importing authority questions the value addition shown in the certificate, it must seek verification from the issuing authority in Thailand rather than rely only on domestic statements or collected material. Because the prescribed verification procedure was not followed, the notice and the order denying preferential tariff concession were contrary to the Rules, and the exemption denial, consequential demands and penalties were set aside.
Where imported goods are supported by Certificates of Origin issued by the designated authority of the exporting country, any reasonable doubt about authenticity or origin particulars must be addressed through the retroactive verification mechanism under Rule 15 of Annexure B to the Interim Rules of Origin. If the importing authority questions the value addition shown in the certificate, it must seek verification from the issuing authority in Thailand rather than rely only on domestic statements or collected material. Because the prescribed verification procedure was not followed, the notice and the order denying preferential tariff concession were contrary to the Rules, and the exemption denial, consequential demands and penalties were set aside.
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