Transaction value rejection limited to FIAT like facts; sub cost sales not automatically subject to reassessment under valuation rules. The circular limits rejection of declared transaction value to cases matching the factual scope of the FIAT judgment and excludes a general rule that sub cost selling alone permits rejection. Officers should verify loss making pricing during audits, using CAS 4 for cost calculations and accepting accountant certified data unless Commissioner authorises cost audit or summons. The circular treats abnormally low pricing as extra commercial consideration for post judgment sales-potentially amounting to wilful misstatement-but advises that for periods before the judgment extended limitation may not apply where FIAT alone is the basis for scrutiny.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Transaction value rejection limited to FIAT like facts; sub cost sales not automatically subject to reassessment under valuation rules.
The circular limits rejection of declared transaction value to cases matching the factual scope of the FIAT judgment and excludes a general rule that sub cost selling alone permits rejection. Officers should verify loss making pricing during audits, using CAS 4 for cost calculations and accepting accountant certified data unless Commissioner authorises cost audit or summons. The circular treats abnormally low pricing as extra commercial consideration for post judgment sales-potentially amounting to wilful misstatement-but advises that for periods before the judgment extended limitation may not apply where FIAT alone is the basis for scrutiny.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
