Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Transaction value - Valuation (Customs) - Special or abnormal discount to the related buyers which were in excess of 3% discount - The Appellate Tribunal observed that the discounts were not deemed exclusive to related parties, and thus did not influence the transaction value. The Tribunal found that the department failed to provide concrete reasons to discard the declared transaction value. The arguments against accepting the transaction value were based on conjecture and lacked factual substantiation. In conclusion, the Tribunal set aside the impugned order, stating that the appellant had successfully proven that the declared price reflected the true transaction value.
Transaction value - Valuation (Customs) - Special or abnormal discount to the related buyers which were in excess of 3% discount - The Appellate Tribunal observed that the discounts were not deemed exclusive to related parties, and thus did not influence the transaction value. The Tribunal found that the department failed to provide concrete reasons to discard the declared transaction value. The arguments against accepting the transaction value were based on conjecture and lacked factual substantiation. In conclusion, the Tribunal set aside the impugned order, stating that the appellant had successfully proven that the declared price reflected the true transaction value.
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