Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
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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