Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Declared transaction value for imported second-hand machinery was held to remain acceptable where the load port Chartered Engineer's certificate supported the valuation and no relationship, extra remittance, or other circumstance displacing transaction value was shown. The customs authorities had merely substituted a local Chartered Engineer's certificate, based on unspecified market enquiries and without disclosed technical basis or testing, for contemporaneous import evidence. The Tribunal held that, in the absence of a speaking order and without challenging the genuineness of the load port certificate, rejection of the declared value and enhancement of value were untenable. The appellate order was set aside and assessment under Section 14 was directed on the declared value.
Declared transaction value for imported second-hand machinery was held to remain acceptable where the load port Chartered Engineer's certificate supported the valuation and no relationship, extra remittance, or other circumstance displacing transaction value was shown. The customs authorities had merely substituted a local Chartered Engineer's certificate, based on unspecified market enquiries and without disclosed technical basis or testing, for contemporaneous import evidence. The Tribunal held that, in the absence of a speaking order and without challenging the genuineness of the load port certificate, rejection of the declared value and enhancement of value were untenable. The appellate order was set aside and assessment under Section 14 was directed on the declared value.
Note: It is a system-generated summary and is for quick reference only.