Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
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Extended limitation was held applicable because the investigation materials showed wilful misstatement and suppression of facts, including diversion of duty-free imports, use of an incorrect export code, and alleged manipulation of export documentation. The plea that the discrepancy was merely clerical was rejected, and the show cause notice was treated as timely. The requirement of pre-deposit was also upheld as reasonable because the appellants could not rely on parity with an earlier order involving different facts and limited bills of entry. On that basis, the direction to deposit amounts and the dismissal of the appeals for non-compliance were sustained.
Extended limitation was held applicable because the investigation materials showed wilful misstatement and suppression of facts, including diversion of duty-free imports, use of an incorrect export code, and alleged manipulation of export documentation. The plea that the discrepancy was merely clerical was rejected, and the show cause notice was treated as timely. The requirement of pre-deposit was also upheld as reasonable because the appellants could not rely on parity with an earlier order involving different facts and limited bills of entry. On that basis, the direction to deposit amounts and the dismissal of the appeals for non-compliance were sustained.
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