Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
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Related-party imports can justify rejection of declared transaction value where the importer and foreign supplier are owned or controlled by the same family and the relationship was not disclosed; the Tribunal treated this as sufficient reason to doubt the truth of the declared value under the valuation rules. Once transaction value is rejected, re-determination must follow the prescribed sequential valuation scheme, with a rule-by-rule basis identified for each item. The Tribunal sustained valuation only for specified goods where supplier invoices or contemporaneous imports supported the adjustment, but set aside Rule 8 valuations based on unsupported materials such as manufacturers' invoices, handwritten cost sheets, domestic sale prices, or arbitrary loading. Consequential confiscation, redemption fine, and personal penalties were quashed.
Related-party imports can justify rejection of declared transaction value where the importer and foreign supplier are owned or controlled by the same family and the relationship was not disclosed; the Tribunal treated this as sufficient reason to doubt the truth of the declared value under the valuation rules. Once transaction value is rejected, re-determination must follow the prescribed sequential valuation scheme, with a rule-by-rule basis identified for each item. The Tribunal sustained valuation only for specified goods where supplier invoices or contemporaneous imports supported the adjustment, but set aside Rule 8 valuations based on unsupported materials such as manufacturers' invoices, handwritten cost sheets, domestic sale prices, or arbitrary loading. Consequential confiscation, redemption fine, and personal penalties were quashed.
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