Section 80P business attribution: ITAT allows deduction on investment interest and ancillary receipts, but excludes staff-loan and other non-eligible ...
Related-party imports justified rejection of the declared transaction value because common ownership and control created reasonable doubt as to its truth and accuracy under Rule 10A. After that rejection, valuation had to proceed strictly in sequence under the Customs Valuation Rules; a composite and unsupported resort to Rule 8, including use of domestic sale prices and an assumed average undervaluation, was unsustainable. Only the leather straps valuation was supported by duplicate invoices and could be adopted under Rule 5, so the demand was sustained only to that limited extent, while confiscation, redemption fine and penalties fell with the reassessment.
Related-party imports justified rejection of the declared transaction value because common ownership and control created reasonable doubt as to its truth and accuracy under Rule 10A. After that rejection, valuation had to proceed strictly in sequence under the Customs Valuation Rules; a composite and unsupported resort to Rule 8, including use of domestic sale prices and an assumed average undervaluation, was unsustainable. Only the leather straps valuation was supported by duplicate invoices and could be adopted under Rule 5, so the demand was sustained only to that limited extent, while confiscation, redemption fine and penalties fell with the reassessment.
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