Person chargeable with duty must be the importer at importation; subsequent purchasers cannot be held liable where beneficial owner rules did not appl...
Statutory exemption under section 10(26AAB) for an Agricultural Produce Marketing Committee could not be denied merely because the PAN reflected an incorrect status as a trust. The ITAT held that the assessee's true character as an Agricultural Produce Marketing Committee was undisputed, and a mismatched PAN entry was not determinative of the legal position or a basis to tax otherwise exempt income. On that footing, the assessment orders were set aside on merits, the AO was directed to compute total income at nil, and the reopening grounds were left undecided because no taxable income survived.
Statutory exemption under section 10(26AAB) for an Agricultural Produce Marketing Committee could not be denied merely because the PAN reflected an incorrect status as a trust. The ITAT held that the assessee's true character as an Agricultural Produce Marketing Committee was undisputed, and a mismatched PAN entry was not determinative of the legal position or a basis to tax otherwise exempt income. On that footing, the assessment orders were set aside on merits, the AO was directed to compute total income at nil, and the reopening grounds were left undecided because no taxable income survived.
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