Minimum alternate tax exclusions for pre-amendment banking companies and expatriate Indian branch salaries remain outside head office expenditure limi...
Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Related-party customs valuation was re-opened because later investigation disclosed fresh agreements, merger-related changes and different valuation methodologies, so earlier SVB and Tribunal orders did not bar reconsideration. The declared transaction value was rejected as not reflecting an uninfluenced price; valuation was directed on the deductive method where list price existed and on the computed method where it did not, with a 38% trade discount, admissible general expenses, and no separate addition for freight or insurance. Exemption under Notification No. 89/1982-Cus. was denied for SAD under strict construction, the extended limitation period was upheld for suppression, confiscation on an unnotified ground was set aside, and interest and penalty survived only for the BCD component.
Related-party customs valuation was re-opened because later investigation disclosed fresh agreements, merger-related changes and different valuation methodologies, so earlier SVB and Tribunal orders did not bar reconsideration. The declared transaction value was rejected as not reflecting an uninfluenced price; valuation was directed on the deductive method where list price existed and on the computed method where it did not, with a 38% trade discount, admissible general expenses, and no separate addition for freight or insurance. Exemption under Notification No. 89/1982-Cus. was denied for SAD under strict construction, the extended limitation period was upheld for suppression, confiscation on an unnotified ground was set aside, and interest and penalty survived only for the BCD component.
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