Revenue authority mandates using scheme-specific reversal procedures, not revising original entries, for instrument-based trade/customs benefits effec...
Transaction value under s.15(1) governs unrelated sales; valuation between related parties per Rule 28; consignment note required for unregistered rec...
The ITAT held that the 10% tolerance band in the proviso to s.43CA applies retrospectively to the year under consideration, such that where the difference between the DVO valuation and sale consideration is within 10% no deeming addition arises. Applying the proviso and the Tribunal's precedent, the panel found the variance fell within the tolerance band for AY 2017-18 and therefore deleted the addition under s.43CA. The Tribunal affirmed the CIT(A)'s deletion of the addition, concluding there was no infirmity in treating the sale consideration as the full value of consideration for the impugned assessment year. Decided in favour of assessee.
The ITAT held that the 10% tolerance band in the proviso to s.43CA applies retrospectively to the year under consideration, such that where the difference between the DVO valuation and sale consideration is within 10% no deeming addition arises. Applying the proviso and the Tribunal's precedent, the panel found the variance fell within the tolerance band for AY 2017-18 and therefore deleted the addition under s.43CA. The Tribunal affirmed the CIT(A)'s deletion of the addition, concluding there was no infirmity in treating the sale consideration as the full value of consideration for the impugned assessment year. Decided in favour of assessee.
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