Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Imported embroidery threads were re-valued on the basis of the full transaction value because supplementary invoices and admitted extra payments showed that part of the price had been kept outside the banking channel. The absence of comparable import data did not defeat the demand, since the undervaluation was supported by the appellants' own documents and admissions. The Tribunal sustained the differential customs duty after re-determining the assessable value under the valuation rules, and upheld penalties on both the importer and its Director because the same evidence established suppression and wilful misstatement.
Imported embroidery threads were re-valued on the basis of the full transaction value because supplementary invoices and admitted extra payments showed that part of the price had been kept outside the banking channel. The absence of comparable import data did not defeat the demand, since the undervaluation was supported by the appellants' own documents and admissions. The Tribunal sustained the differential customs duty after re-determining the assessable value under the valuation rules, and upheld penalties on both the importer and its Director because the same evidence established suppression and wilful misstatement.
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