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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...
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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...
CESTAT partially allowed the appeal, upholding the inclusion of metal lease charges and insurance premium in assessable value. The tribunal set aside the extended period of limitation and penalty under section 114A of Customs Act. The appellant's claim for refund was rejected, with the Principal Commissioner's findings deemed legally valid. The decision affirmed that insurance premium constituted a condition of sale and metal lease charges were not considered interest. The tribunal found no willful suppression of facts by the importer, who had consistently paid excess customs duty based on actual gold content in invoices.
CESTAT partially allowed the appeal, upholding the inclusion of metal lease charges and insurance premium in assessable value. The tribunal set aside the extended period of limitation and penalty under section 114A of Customs Act. The appellant's claim for refund was rejected, with the Principal Commissioner's findings deemed legally valid. The decision affirmed that insurance premium constituted a condition of sale and metal lease charges were not considered interest. The tribunal found no willful suppression of facts by the importer, who had consistently paid excess customs duty based on actual gold content in invoices.
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