Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Activity trackers/fitness bands were held classifiable under CTI 8517 6290 because their principal function extended beyond pedometer-like step counting and included tracking and communication-linked fitness outputs through a paired application; the residual tariff entry was therefore applied and the classification under CTI 9029 1090 was rejected. The extended period of limitation was not available because the classification issue was already within departmental knowledge, the goods had been examined under customs control, and no suppression, wilful misstatement, collusion or fraud was shown. Only differential duty with applicable interest for the normal period was sustained. Alleged DGFT labelling non-compliance did not justify confiscation, redemption fine or penalty.
Activity trackers/fitness bands were held classifiable under CTI 8517 6290 because their principal function extended beyond pedometer-like step counting and included tracking and communication-linked fitness outputs through a paired application; the residual tariff entry was therefore applied and the classification under CTI 9029 1090 was rejected. The extended period of limitation was not available because the classification issue was already within departmental knowledge, the goods had been examined under customs control, and no suppression, wilful misstatement, collusion or fraud was shown. Only differential duty with applicable interest for the normal period was sustained. Alleged DGFT labelling non-compliance did not justify confiscation, redemption fine or penalty.
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