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...
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursement...
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Customs exemption amendments cannot be applied to imported second-hand specialised equipment handed to the first carrier before the amendment took effect, where multimodal transport is recognised under the Customs Act. A request for provisional release must therefore be considered under Section 110A and cannot be refused merely by relying on the subsequent amendment. Earlier directions concerning provisional release of similar goods remain applicable where no distinguishing feature exists. Upon compliance with lawful conditions, the goods are to be provisionally released pending adjudication.
Customs exemption amendments cannot be applied to imported second-hand specialised equipment handed to the first carrier before the amendment took effect, where multimodal transport is recognised under the Customs Act. A request for provisional release must therefore be considered under Section 110A and cannot be refused merely by relying on the subsequent amendment. Earlier directions concerning provisional release of similar goods remain applicable where no distinguishing feature exists. Upon compliance with lawful conditions, the goods are to be provisionally released pending adjudication.
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