Authentication of paper assessment orders upheld, while qualifying repairs, consumables and vendor advance write-offs remain deductible business claim...
Transaction value cannot be rejected solely on non-statutory valuation guidelines without corroborative evidence supporting reassessment of final cust...
Cross-examination rights and corroborated evidence limit customs penalties for misdeclaration in genuine import transactions involving documented clea...
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Reopening of assessment u/s 147 - initiating notice u/s 148A(b) - alleged information received from DDIT (Inv.), Mumbai that the petitioner opted accommodation entries - The High court noted that the purpose of the inquiry u/s 148A was to determine whether a case for reassessment was made out. It found that the petitioner's admission of the transaction between him and AEPL, not being reflected in the income tax return, constituted a prima facie case for reopening the assessment. - Further, the HC held that the objections raised by the petitioner were more in the nature of explaining why the transaction amount should not be taxable, which would be examined in detail during reassessment proceedings.
Reopening of assessment u/s 147 - initiating notice u/s 148A(b) - alleged information received from DDIT (Inv.), Mumbai that the petitioner opted accommodation entries - The High court noted that the purpose of the inquiry u/s 148A was to determine whether a case for reassessment was made out. It found that the petitioner's admission of the transaction between him and AEPL, not being reflected in the income tax return, constituted a prima facie case for reopening the assessment. - Further, the HC held that the objections raised by the petitioner were more in the nature of explaining why the transaction amount should not be taxable, which would be examined in detail during reassessment proceedings.
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