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...
Bluetooth wireless earphones, headphones, earbuds and neckbands were classified as headphones or earphones under CTI 8518 30 00 because their objective character and commercial identity fell within the specific eo nomine heading for audio reproduction devices. Bluetooth connectivity was treated as only the means of linking to a device, not as altering the essential nature of the goods into data transmission equipment, so the broader residual heading in 8517 was rejected. The concessional notification linked to CTI 8517 62 90 was therefore unavailable, and the duty demand was sustainable on merits. However, the extended period of limitation was not justified because the dispute was one of classification and intent to evade duty was not established; penalty under section 114A also could not survive. The matter was remitted only for the normal-period demand and consequential interest.
Bluetooth wireless earphones, headphones, earbuds and neckbands were classified as headphones or earphones under CTI 8518 30 00 because their objective character and commercial identity fell within the specific eo nomine heading for audio reproduction devices. Bluetooth connectivity was treated as only the means of linking to a device, not as altering the essential nature of the goods into data transmission equipment, so the broader residual heading in 8517 was rejected. The concessional notification linked to CTI 8517 62 90 was therefore unavailable, and the duty demand was sustainable on merits. However, the extended period of limitation was not justified because the dispute was one of classification and intent to evade duty was not established; penalty under section 114A also could not survive. The matter was remitted only for the normal-period demand and consequential interest.
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