Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Assessable value of a body-built motor vehicle manufactured on job work includes the chassis value on which duty was paid, including the additional margin applied under Rule 8, together with the job worker's material cost, expenses and profit. The manufacturer's anticipated resale profit and post-receipt expenses remain excluded. Although this valuation component was required to be included, extended limitation for duty recovery requires fraud, collusion, wilful misstatement, wilful suppression, or intent to evade duty. Departmental knowledge that the chassis had been valued at 110% of manufacturing cost precluded treating the job worker's omission as wilful suppression. A notice issued beyond the ordinary limitation period was therefore time-barred, resulting in the demand and penalty being set aside.
Assessable value of a body-built motor vehicle manufactured on job work includes the chassis value on which duty was paid, including the additional margin applied under Rule 8, together with the job worker's material cost, expenses and profit. The manufacturer's anticipated resale profit and post-receipt expenses remain excluded. Although this valuation component was required to be included, extended limitation for duty recovery requires fraud, collusion, wilful misstatement, wilful suppression, or intent to evade duty. Departmental knowledge that the chassis had been valued at 110% of manufacturing cost precluded treating the job worker's omission as wilful suppression. A notice issued beyond the ordinary limitation period was therefore time-barred, resulting in the demand and penalty being set aside.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4803
Join Channel
TaxTMI 
