Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
Related-party customs valuation cannot be rejected where the relationship has not influenced price, especially when the imports form part of composite EPC contracts awarded through international competitive bidding to the lowest bidder. The Tribunal accepted that the declared transaction value was correctly taken because the pricing was transparent and independent, and bankers' documents relied on to allege overvaluation lacked the required certificate under the Customs Act, so they could not justify rejection of value. Once misdeclaration of value failed, confiscation for misdeclaration and the consequential penalties under the Customs Act also failed. The department's appeals were dismissed.
Related-party customs valuation cannot be rejected where the relationship has not influenced price, especially when the imports form part of composite EPC contracts awarded through international competitive bidding to the lowest bidder. The Tribunal accepted that the declared transaction value was correctly taken because the pricing was transparent and independent, and bankers' documents relied on to allege overvaluation lacked the required certificate under the Customs Act, so they could not justify rejection of value. Once misdeclaration of value failed, confiscation for misdeclaration and the consequential penalties under the Customs Act also failed. The department's appeals were dismissed.
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