TNMM comparability using audited accounts and working-capital adjustments can eliminate unwarranted transfer-pricing additions where verified margins ...
Gross-profit additions on disputed purchases require reasoned appellate determination; disclosed claims alone do not support inaccurate-particulars pe...
Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barr...
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursement...
Palmolein classification defeated the crude-oil concession; material misdeclaration sustained recovery and confiscation, while separate false-document...
Provisional release of seized Ketamine Hydrochloride for export was warranted where a fresh export authorisation covered the same goods after the original authorisation had expired following replacement of the shipment batch. The High Court treated the delay in obtaining the fresh authorisation as technical because the goods remained unexported and the licensing authority had accepted the new authorisation as valid. Customs could not deny its effect merely because the licensing authority had not expressly authorised release of the seized goods. Union departments must maintain consistent positions on the same export transaction. The rejection of provisional release was quashed, subject to a Customs deposit, while adjudication and criminal proceedings remained unaffected.
Provisional release of seized Ketamine Hydrochloride for export was warranted where a fresh export authorisation covered the same goods after the original authorisation had expired following replacement of the shipment batch. The High Court treated the delay in obtaining the fresh authorisation as technical because the goods remained unexported and the licensing authority had accepted the new authorisation as valid. Customs could not deny its effect merely because the licensing authority had not expressly authorised release of the seized goods. Union departments must maintain consistent positions on the same export transaction. The rejection of provisional release was quashed, subject to a Customs deposit, while adjudication and criminal proceedings remained unaffected.
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