Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
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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