Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
Where the proper officer verifies a certificate of origin under the preferential tariff scheme, provisional release of imported goods must preserve revenue protection. The High Court stressed judicial restraint in revenue matters and required strict compliance with the Act, Rules and Circular governing such verification. Because verification had been delayed, the Court directed completion within three weeks. If the declared country of origin is confirmed, release is to follow in accordance with law; if it is found incorrect or false, provisional release must be supported by a 100% bank guarantee as prescribed in the circular.
Where the proper officer verifies a certificate of origin under the preferential tariff scheme, provisional release of imported goods must preserve revenue protection. The High Court stressed judicial restraint in revenue matters and required strict compliance with the Act, Rules and Circular governing such verification. Because verification had been delayed, the Court directed completion within three weeks. If the declared country of origin is confirmed, release is to follow in accordance with law; if it is found incorrect or false, provisional release must be supported by a 100% bank guarantee as prescribed in the circular.
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