Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
Valuation of export goods - Iron Ore Fines - transaction value - FOB price - Export duty - The appellant contested this, arguing that unless the Revenue disputes the transaction value with corroborative evidence, it should be considered valid, citing relevant case laws. The Tribunal concurred, emphasizing that the Revenue had not doubted the transaction value and had not followed sequential valuation rules before adopting contemporaneous values. As the Revenue did not contest the Adjudicating Authority's findings, the transaction value's correctness was upheld, and the appeal was allowed.
Valuation of export goods - Iron Ore Fines - transaction value - FOB price - Export duty - The appellant contested this, arguing that unless the Revenue disputes the transaction value with corroborative evidence, it should be considered valid, citing relevant case laws. The Tribunal concurred, emphasizing that the Revenue had not doubted the transaction value and had not followed sequential valuation rules before adopting contemporaneous values. As the Revenue did not contest the Adjudicating Authority's findings, the transaction value's correctness was upheld, and the appeal was allowed.
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TaxTMI 
TaxTMI 
of 4918 
