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    Accommodation entry addition deleted where Revenue failed to prove bogus billing and denied cross-examination of relied-on statement.
    Indexed improvement cost and section 54 relief allowed on reasonable construction basis and full eligible investment, excluding club charges.
    Make available test under India-UAE DTAA barred tax on advisory fees absent technical know-how transfer and permanent establishment.
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      The Tribunal held that its earlier provisional release order...

      Mistake apparent from record was not shown in provisional release conditions; rectification was refused, with clarification left open.

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      CustomsApril 24, 2026Case LawsAT
      The Tribunal held that its earlier provisional release order under Section 110A was an interim arrangement balancing both sides and had already contemplated movement of goods from an SEZ unit to another SEZ unit, an EOU, or the DTA, as well as return-linked adjustment of the bank guarantee. The contingency later projected by the applicant was therefore not an apparent mistake on the record, and the plea of possible double duty did not justify rectification. Any operational difficulty in applying the release conditions could only be addressed by clarification, not by review through a ROM application. The rectification request was dismissed, while the Tribunal directed expeditious completion of the investigation.

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      ActsIncome Tax