Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
Integrated drive generators and starter generators imported for use with turboprop or turbofan engines were held classifiable under heading 8501, not heading 8511, because heading 8511 applies only to generators used with spark-ignition or compression-ignition internal combustion engines. Applying Rule 1 of the General Rules of Interpretation and the HSN notes, the Tribunal rejected the department's classification and accepted the importer's claim under heading 8501. It further held that a mere classification dispute did not justify the extended period of limitation or penalty under section 114A, absent collusion, wilful misstatement or suppression. The residuary penalty on the customs broker under section 117 was also set aside because it had acted on the importer's documents and instructions.
Integrated drive generators and starter generators imported for use with turboprop or turbofan engines were held classifiable under heading 8501, not heading 8511, because heading 8511 applies only to generators used with spark-ignition or compression-ignition internal combustion engines. Applying Rule 1 of the General Rules of Interpretation and the HSN notes, the Tribunal rejected the department's classification and accepted the importer's claim under heading 8501. It further held that a mere classification dispute did not justify the extended period of limitation or penalty under section 114A, absent collusion, wilful misstatement or suppression. The residuary penalty on the customs broker under section 117 was also set aside because it had acted on the importer's documents and instructions.
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