Retrospective invalidity of ocean-freight IGST supports refunds despite non-party status and prior credit utilisation, subject to authorised appeal gr...
Additional evidence in departmental appeals may include show-cause-notice material without introducing a new case where it merely corroborates existin...
Reasoned rectification orders require consideration of expenditure disclosed in income-tax returns, preventing revision based on incomplete income com...
Modified returns after business reorganisations cannot trigger fresh scrutiny once the original assessment was complete, invalidating related transfer...
Third-party loose sheets require reliable nexus before supporting unexplained expenditure additions; presumptions do not establish payer identity or o...
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...
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Excise liability for modifications to fully built motor vehicles depends on whether refining or remaking amounts to manufacture and, where a Chapter Note is invoked, whether a body was built on the chassis as received. These foundational questions require fresh determination before excisability and chassis-based exemption can be resolved. Extended limitation requires a positive, deliberate suppression or misstatement intended to evade duty; registration, returns, departmental scrutiny and a bona fide exemption belief do not establish that standard merely because the departmental view later changes. Any duty determined is confined to the normal limitation period. Penalties for the manufacturer and its Executive Director require the same fraud or intentional-evasion conditions and therefore do not arise absent such conduct.
Excise liability for modifications to fully built motor vehicles depends on whether refining or remaking amounts to manufacture and, where a Chapter Note is invoked, whether a body was built on the chassis as received. These foundational questions require fresh determination before excisability and chassis-based exemption can be resolved. Extended limitation requires a positive, deliberate suppression or misstatement intended to evade duty; registration, returns, departmental scrutiny and a bona fide exemption belief do not establish that standard merely because the departmental view later changes. Any duty determined is confined to the normal limitation period. Penalties for the manufacturer and its Executive Director require the same fraud or intentional-evasion conditions and therefore do not arise absent such conduct.
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