Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
For IGST classification, the tariff heading used in the rate notification was treated as inseparably linked to the goods description, so the Department could not shift the goods to a residual entry without first challenging the importer's self-assessed classification under heading 8432. As the show cause notice did not seek reclassification or dispute that classification, a higher IGST demand under the residual serial could not be sustained and the appellate remand for fresh adjudication was unwarranted. The Tribunal also held that the extended limitation period was unavailable because the notice did not establish wilful misstatement, collusion or suppression of facts. The remand was set aside and the order dropping the demand was restored.
For IGST classification, the tariff heading used in the rate notification was treated as inseparably linked to the goods description, so the Department could not shift the goods to a residual entry without first challenging the importer's self-assessed classification under heading 8432. As the show cause notice did not seek reclassification or dispute that classification, a higher IGST demand under the residual serial could not be sustained and the appellate remand for fresh adjudication was unwarranted. The Tribunal also held that the extended limitation period was unavailable because the notice did not establish wilful misstatement, collusion or suppression of facts. The remand was set aside and the order dropping the demand was restored.
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