Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
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Valuation - transaction value of food supplements imported - undervaluation and mis-declaration of goods - rejection of declared value - In the present case, it is observed that SG has categorically admitted for having discussed with the Foreign suppliers about the actual price and that the said actual prices were mentioned on the invoices received from the foreign suppliers. It is thereafter that Shri SG used to prepare fake invoices in his computer reducing the price of the invoices of foreign supplier to the extent of almost 50% thereof so as to file the same along with Bill of Entry - However, the order of demand and imposition of penalty on other importing firms and their respective proprietors is hereby set aside. - AT
Valuation - transaction value of food supplements imported - undervaluation and mis-declaration of goods - rejection of declared value - In the present case, it is observed that SG has categorically admitted for having discussed with the Foreign suppliers about the actual price and that the said actual prices were mentioned on the invoices received from the foreign suppliers. It is thereafter that Shri SG used to prepare fake invoices in his computer reducing the price of the invoices of foreign supplier to the extent of almost 50% thereof so as to file the same along with Bill of Entry - However, the order of demand and imposition of penalty on other importing firms and their respective proprietors is hereby set aside. - AT
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