Prior APA methodology guides transfer pricing benchmarking where consistent FAR profiles support comparability and arm's length margins eliminate adju...
Battery-integrated tablet rear covers classify as lithium-ion accumulators when protective components enable the battery's active energy-storage funct...
Natural justice was prima facie breached where an unexplained-expenditure addition based on import data was made without meaningful invoice-wise or bill-of-entry-wise particulars. Recorded imports supplied by the assessee exceeded the aggregate data relied on, and apparent duplication in departmental data prevented reconciliation. The High Court treated the addition as raising strong triable issues and stayed recovery pending first appeal, while requiring the appellate authority to decide independently on merits. Administrative directions concerning deposit of a prescribed demand percentage did not fetter the Court's stay power; Revenue's insistence on a 20% payment was rejected. The assessment observations remained confined to the prima facie stay determination.
Natural justice was prima facie breached where an unexplained-expenditure addition based on import data was made without meaningful invoice-wise or bill-of-entry-wise particulars. Recorded imports supplied by the assessee exceeded the aggregate data relied on, and apparent duplication in departmental data prevented reconciliation. The High Court treated the addition as raising strong triable issues and stayed recovery pending first appeal, while requiring the appellate authority to decide independently on merits. Administrative directions concerning deposit of a prescribed demand percentage did not fetter the Court's stay power; Revenue's insistence on a 20% payment was rejected. The assessment observations remained confined to the prima facie stay determination.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
