Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
Automotive sensor classification depends on the imported article's objective characteristics and independent function: temperature sensors that only transmit resistance signals fall under the specific thermistor entry; exhaust-gas sensors performing electrochemical analysis fall under gas-analysis apparatus; a brake-pedal sensor remains a Chapter 90 measuring or checking instrument rather than a brake part; and a Hall-effect wheel sensor that generates pulses is electrical apparatus, not a speed-measuring instrument. Specific tariff headings prevail over residual headings. Completed nil-duty assessments cannot be reclassified through duty-recovery proceedings without a proposed duty liability. Alternate FTA relief requires proof of eligibility, revenue neutrality does not ordinarily eliminate duty, extended limitation requires intentional misstatement or suppression, and import IGST interest needs express statutory authority.
Automotive sensor classification depends on the imported article's objective characteristics and independent function: temperature sensors that only transmit resistance signals fall under the specific thermistor entry; exhaust-gas sensors performing electrochemical analysis fall under gas-analysis apparatus; a brake-pedal sensor remains a Chapter 90 measuring or checking instrument rather than a brake part; and a Hall-effect wheel sensor that generates pulses is electrical apparatus, not a speed-measuring instrument. Specific tariff headings prevail over residual headings. Completed nil-duty assessments cannot be reclassified through duty-recovery proceedings without a proposed duty liability. Alternate FTA relief requires proof of eligibility, revenue neutrality does not ordinarily eliminate duty, extended limitation requires intentional misstatement or suppression, and import IGST interest needs express statutory authority.
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