Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Turnover mismatches under percentage-completion accounting cannot alone establish suppressed income where customer advances remain recorded as liabili...
Customs Valuation Rules 2007 - Rule 12 allows rejection of declared transaction value and re-determination u/r 9 if identical/similar goods imported at comparable time/quantities/commercial transactions at higher value. JSB Aluminium admitted declared value lower, accepted re-determination at higher price. Assessing Officer not required to give reasons for rejection when value admitted lower. Supreme Court precedents - admitted facts need not be proved, transaction value rejectable without cogent evidence if value admitted lower. Commissioner (Appeals) order allowing appeals set aside, appeal by department allowed.
Customs Valuation Rules 2007 - Rule 12 allows rejection of declared transaction value and re-determination u/r 9 if identical/similar goods imported at comparable time/quantities/commercial transactions at higher value. JSB Aluminium admitted declared value lower, accepted re-determination at higher price. Assessing Officer not required to give reasons for rejection when value admitted lower. Supreme Court precedents - admitted facts need not be proved, transaction value rejectable without cogent evidence if value admitted lower. Commissioner (Appeals) order allowing appeals set aside, appeal by department allowed.
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TaxTMI 
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