Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Valuation of imported goods - undervaluation - Proforma invoice - When the department conducted market survey and the persons were there witness, it was their duty to mention name of person on such Proforma invoice or to find such person from cross examination as the Appellant were not made present during market survey. The market survey was conducted in absence of Appellant and they could not be expected to name the person who has issued such Proforma invoice. When the revenue itself does not knows as to who has issued such Proforma invoice and there is no statements of makers of such invoice, in that case the Proforma invoices has no evidentiary value. - AT
Valuation of imported goods - undervaluation - Proforma invoice - When the department conducted market survey and the persons were there witness, it was their duty to mention name of person on such Proforma invoice or to find such person from cross examination as the Appellant were not made present during market survey. The market survey was conducted in absence of Appellant and they could not be expected to name the person who has issued such Proforma invoice. When the revenue itself does not knows as to who has issued such Proforma invoice and there is no statements of makers of such invoice, in that case the Proforma invoices has no evidentiary value. - AT
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