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...
Valuation of imported goods - Polyurethane Sealant - enhancement of value solely based on appellant's acceptance letter whereby price was increased 5 times declared value. Held: Value enhanced solely on acceptance letter dated 26.07.2018 by appellant. As per CMR Nikkei India Pvt. Ltd case, despite importer's admission, Revenue must satisfy Section 14 of Customs Act and Customs Valuation Rules before enhancing valuation. Only acceptance letter relied upon, no contemporaneous import price based on documentary evidence. Therefore, no reason to enhance value. Both lower Authorities' orders incorrect and illegal. Sukhdev Exports Overseas case involving statement u/s 108 not applicable as no such statement recorded here. Impugned order set aside - appeal allowed.
Valuation of imported goods - Polyurethane Sealant - enhancement of value solely based on appellant's acceptance letter whereby price was increased 5 times declared value. Held: Value enhanced solely on acceptance letter dated 26.07.2018 by appellant. As per CMR Nikkei India Pvt. Ltd case, despite importer's admission, Revenue must satisfy Section 14 of Customs Act and Customs Valuation Rules before enhancing valuation. Only acceptance letter relied upon, no contemporaneous import price based on documentary evidence. Therefore, no reason to enhance value. Both lower Authorities' orders incorrect and illegal. Sukhdev Exports Overseas case involving statement u/s 108 not applicable as no such statement recorded here. Impugned order set aside - appeal allowed.
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