Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
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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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