Trademark depreciation and section 14A adjustments: ITAT applies consistency, independent book-profit computation, and no disallowance without exempt ...
Rebuttable search presumptions and corroboration standards shaped deletion of unsubstantiated additions, while rental income and limited profit estima...
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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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