The Tribunal struck down reopening where reasons conflicted and rested solely on AIR cash-deposit data. The key takeaway is that reassessment needs a clear, reasoned nexus.
The tribunal held that city seizure of gold without foreign markings or import evidence cannot be treated as smuggling. In the absence of proof of foreign origin, confiscation and penalties were set aside.
The issue was whether customs duty could be demanded from a transferee using DFIA licences allegedly obtained by exporter misrepresentation. The Tribunal held that extended limitation cannot apply where no fraud or suppression is alleged against the importer.
Supreme Court upheld the quashing of reassessment where scrutiny queries on deductions were earlier examined. It held that reopening based only on reappraisal of the same material amounts to an impermissible change of opinion.
The Court held that relief cannot be denied under Section 264 merely because a similar issue was earlier pending before the Supreme Court. The revision application was allowed as the issue was already covered by binding High Court rulings.
The ruling set aside a large AMP adjustment after finding that commission paid to distributors could not be recharacterized as marketing expenditure. Consistency with prior years played a decisive role in deleting the adjustment.
The issue was whether the Assessing Officer could alter income despite a valid APA and modified return. The Court held that without an adverse TPO audit or APA cancellation, reassessment adjustments were without jurisdiction.
The dispute centered on whether a reassessment notice was time-barred and sanctioned by the correct authority. The Tribunal held that the reply period under section 148A must be excluded, bringing the notice within three years and validating the sanction.
The authority examined whether plastic filter tips used with automated instruments were machine parts and held they were disposable consumables, classifiable as articles of plastic under CTH 39269099.
The authority held that molecular biology kits containing nucleic acids are chemically defined compounds classifiable under Chapter 29, rejecting classification as laboratory reagents under Chapter 38.
