Risk-based postal import clearance standardises electronic assessment, document requests, duty realisation and delivery controls at Foreign Post Offic...
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Post-search scrutiny assessment remains available where original assessment limitation is unexpired, permitting timely completion under regular assess...
Reopening of assessment was upheld where the recorded reasons showed fresh tangible material from impounded documents and a director's statement, and the assessee had not fully disclosed the crucial Clause 7 entitlement to 35% of gross sale receipts; no earlier opinion on the receipt's true character had been formed, so change of opinion did not apply. The Court also held that reopening must stand or fall on the recorded reasons alone. On the merits, the assessee's 35% entitlement under the AOP agreement was not a share of profit, because it arose from gross receipts before project expenses and was diverted by overriding title; it was therefore taxable as business income.
Reopening of assessment was upheld where the recorded reasons showed fresh tangible material from impounded documents and a director's statement, and the assessee had not fully disclosed the crucial Clause 7 entitlement to 35% of gross sale receipts; no earlier opinion on the receipt's true character had been formed, so change of opinion did not apply. The Court also held that reopening must stand or fall on the recorded reasons alone. On the merits, the assessee's 35% entitlement under the AOP agreement was not a share of profit, because it arose from gross receipts before project expenses and was diverted by overriding title; it was therefore taxable as business income.
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