Capital Gain Deductibility: proportionate IPO and PMS expenses held allowable against capital gains where netting and nexus to transfer are establishe...
Admissibility of Documentary Evidence: appellate authority may admit self explanatory documents on first production and uphold deletion of unexplained...
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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