Internal CUP benchmarking for fixed-rate Masala Bonds prevails over floating external comparables, eliminating the related transfer-pricing adjustment...
Jurisdictional validity of revision notices: incorrect official capacity and mere change of opinion invalidate revision of property income assessments...
Bogus-purchase additions are limited to embedded profit where corresponding sales are accepted, while accommodation-entry information can support reas...
Customs valuation safeguards require the proper officer to communicate written reasons for doubting a declared transaction value and disclose relevant contemporaneous import particulars, including quantity, quality and temporal comparability. Acceptance letters given while seeking clearance on payment of duty under protest do not by themselves establish voluntary acceptance of enhanced value or waive these requirements. Written acceptance of reassessment may dispense with a speaking order, but it does not extinguish the statutory right to challenge reassessment on merits. Consent or acquiescence cannot defeat a statutory appeal; enhancement founded solely on undisclosed comparable data and acceptance letters cannot be sustained, and rejection of such appeals must be set aside with consequential relief.
Customs valuation safeguards require the proper officer to communicate written reasons for doubting a declared transaction value and disclose relevant contemporaneous import particulars, including quantity, quality and temporal comparability. Acceptance letters given while seeking clearance on payment of duty under protest do not by themselves establish voluntary acceptance of enhanced value or waive these requirements. Written acceptance of reassessment may dispense with a speaking order, but it does not extinguish the statutory right to challenge reassessment on merits. Consent or acquiescence cannot defeat a statutory appeal; enhancement founded solely on undisclosed comparable data and acceptance letters cannot be sustained, and rejection of such appeals must be set aside with consequential relief.
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