Transfer Pricing Officer jurisdiction is transaction-specific, excluding permanent establishment determinations and requiring independent assessment o...
Rental income valuation requires credible local comparables; family-business salary and commercially expedient unsecured-loan interest remained deduct...
Valuation of imported goods - allegation of over-valuation of the goods - It is true that fraud would vitiate everything, but then fraud has not only to be alleged but also proved. In the present case, the documents that form the basis of the allegation of overvaluation cannot be relied upon by the Department as the same cannot be admitted as evidence under the Customs Act. The allegation of fraud, therefore, has not been proved - the proposition that despite finalization of assessment under section 14 of the Customs Act, the provisions of section 111(m) of the Customs Act can still be invoked cannot be accepted. - AT
Valuation of imported goods - allegation of over-valuation of the goods - It is true that fraud would vitiate everything, but then fraud has not only to be alleged but also proved. In the present case, the documents that form the basis of the allegation of overvaluation cannot be relied upon by the Department as the same cannot be admitted as evidence under the Customs Act. The allegation of fraud, therefore, has not been proved - the proposition that despite finalization of assessment under section 14 of the Customs Act, the provisions of section 111(m) of the Customs Act can still be invoked cannot be accepted. - AT
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TaxTMI 
TaxTMI 
of 4888 
