Tax authority's substitution of projected figures with actuals overturned; original acquisition valuation upheld; transfer pricing issues remitted for...
Beneficial owner held liable for differential customs duty; royalties added under Rule 10(1)(c); confiscation, penalties under s.111(m), s.114A, s.112...
The SC dismissed the SLP, upholding the HC's affirmance of the ITAT's factual conclusion that the AO's addition of alleged outstanding liabilities payable to two banks to the assessee's returned income was justified. The Court held the genuineness and existence of the claimed transactions were questions of fact, noting the absence of sufficient evidentiary material to demonstrate receipt (and subsequent return) of goods or to substantiate the asserted liabilities. No perversity or patent illegality in the concurrent findings of fact was found, and there was no basis to interfere with the impugned HC order sustaining the addition.
The SC dismissed the SLP, upholding the HC's affirmance of the ITAT's factual conclusion that the AO's addition of alleged outstanding liabilities payable to two banks to the assessee's returned income was justified. The Court held the genuineness and existence of the claimed transactions were questions of fact, noting the absence of sufficient evidentiary material to demonstrate receipt (and subsequent return) of goods or to substantiate the asserted liabilities. No perversity or patent illegality in the concurrent findings of fact was found, and there was no basis to interfere with the impugned HC order sustaining the addition.
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