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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Revised Customs prosecution thresholds for precious-metal smuggling may extend to pending complaints if the goods' value is below the updated limit. The later circular changes only the monetary threshold and preserves the earlier circular's other conditions. Neither circular prohibits consideration of withdrawal after prosecution sanction has issued; the Magistrate retains discretion under the earlier framework to decide whether the prosecution should continue. Where withdrawal was rejected solely because sanction had issued, reconsideration under the applicable circulars is required.
Revised Customs prosecution thresholds for precious-metal smuggling may extend to pending complaints if the goods' value is below the updated limit. The later circular changes only the monetary threshold and preserves the earlier circular's other conditions. Neither circular prohibits consideration of withdrawal after prosecution sanction has issued; the Magistrate retains discretion under the earlier framework to decide whether the prosecution should continue. Where withdrawal was rejected solely because sanction had issued, reconsideration under the applicable circulars is required.
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