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...
Prospective operation of exemption notifications prevents a later amendment from governing imports where the bills of lading pre-date its commencement, unless the amendment expressly provides otherwise. Imported second-hand digital multifunction print and copying machines therefore could not be denied consideration for provisional release by applying the subsequent amendment retrospectively. Provisional release must be considered under applicable customs law and may be granted subject to lawful conditions and compliance, without affecting the pending adjudication proceedings.
Prospective operation of exemption notifications prevents a later amendment from governing imports where the bills of lading pre-date its commencement, unless the amendment expressly provides otherwise. Imported second-hand digital multifunction print and copying machines therefore could not be denied consideration for provisional release by applying the subsequent amendment retrospectively. Provisional release must be considered under applicable customs law and may be granted subject to lawful conditions and compliance, without affecting the pending adjudication proceedings.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4912 
