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...
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Appellant challenged inclusion of royalty and cost of advertisement incurred in India in assessable value of imported goods u/rs 10(1)(c) and 10(1)(e) of Customs Valuation Rules 2007 involving related party transaction. SC concurred with CESTAT's view that appellant's obligation under agreement to be responsible for sales, distribution, and expenditure in consultation with seller does not attract Rule 10(1)(e). Appeal dismissed.
Appellant challenged inclusion of royalty and cost of advertisement incurred in India in assessable value of imported goods u/rs 10(1)(c) and 10(1)(e) of Customs Valuation Rules 2007 involving related party transaction. SC concurred with CESTAT's view that appellant's obligation under agreement to be responsible for sales, distribution, and expenditure in consultation with seller does not attract Rule 10(1)(e). Appeal dismissed.
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