Concessional corporate tax option under section 115BAA survives procedural documentary lapses when statutory compliance and earlier exercise are estab...
Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Seized drone components were not shown on the record to constitute complete drones imported in CKD/SKD condition, as the quantities were uneven, imports were spread across multiple Bills of Entry, some parts were domestically procured, and the engineering report was inconclusive. Applying the principle that CKD/SKD treatment requires proof of complete units dismantled for reassembly, and that Customs Tariff interpretation rules cannot be used to read Foreign Trade Policy conditions, the Tribunal rejected the prohibition basis for refusal of provisional release. It also found no factual foundation for invoking public safety or national security, and held that the CBIC circular could not override the statutory scheme. Conditional provisional release was therefore directed.
Seized drone components were not shown on the record to constitute complete drones imported in CKD/SKD condition, as the quantities were uneven, imports were spread across multiple Bills of Entry, some parts were domestically procured, and the engineering report was inconclusive. Applying the principle that CKD/SKD treatment requires proof of complete units dismantled for reassembly, and that Customs Tariff interpretation rules cannot be used to read Foreign Trade Policy conditions, the Tribunal rejected the prohibition basis for refusal of provisional release. It also found no factual foundation for invoking public safety or national security, and held that the CBIC circular could not override the statutory scheme. Conditional provisional release was therefore directed.
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