Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Valuation of imported goods - stamping foils - rejection of declared value - The tribunal found that the department's reliance on proforma invoices for A-grade goods was misplaced, given the appellant's importation of B and C-grade goods. The tribunal also recognized the appellant's submission of contemporaneous import data supporting their declared values. - The tribunal concurred with the appellant that there was no evidence of extra payment to the foreign supplier beyond the invoice values. - Tribunal held that the appellant's declared values were justified, and the initial inculpatory statement could not be relied upon due to the coercive circumstances under which it was obtained.
Valuation of imported goods - stamping foils - rejection of declared value - The tribunal found that the department's reliance on proforma invoices for A-grade goods was misplaced, given the appellant's importation of B and C-grade goods. The tribunal also recognized the appellant's submission of contemporaneous import data supporting their declared values. - The tribunal concurred with the appellant that there was no evidence of extra payment to the foreign supplier beyond the invoice values. - Tribunal held that the appellant's declared values were justified, and the initial inculpatory statement could not be relied upon due to the coercive circumstances under which it was obtained.
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