Authentication of paper assessment orders upheld, while qualifying repairs, consumables and vendor advance write-offs remain deductible business claim...
Transaction value cannot be rejected solely on non-statutory valuation guidelines without corroborative evidence supporting reassessment of final cust...
Cross-examination rights and corroborated evidence limit customs penalties for misdeclaration in genuine import transactions involving documented clea...
Tariff classification of vehicle gear components follows the specific gearing entry, displacing motor-vehicle parts classification and related liabili...
ITAT set aside the CIT(A) order and restored the case to the file of the AO/TPO for de novo adjudication, holding that neither the assessee's nor the TPO's CUP comparables met Rule 10B(2)/(3) comparability standards; the AO/TPO is directed to reassess ALP after identifying or constructing reliable comparables and making appropriate adjustments (including for convertibility/option value, subordination, security, industry risk and coupon structure). The Tribunal also remitted disputed legal/professional, advertising and commission expenses to the AO for verification and determination as capitalisable WIP or allowable revenue expenditure. The Revenue's appeal is allowed for statistical purposes.
ITAT set aside the CIT(A) order and restored the case to the file of the AO/TPO for de novo adjudication, holding that neither the assessee's nor the TPO's CUP comparables met Rule 10B(2)/(3) comparability standards; the AO/TPO is directed to reassess ALP after identifying or constructing reliable comparables and making appropriate adjustments (including for convertibility/option value, subordination, security, industry risk and coupon structure). The Tribunal also remitted disputed legal/professional, advertising and commission expenses to the AO for verification and determination as capitalisable WIP or allowable revenue expenditure. The Revenue's appeal is allowed for statistical purposes.
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