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...
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ITAT dismissed the revenue's appeal and upheld the CIT(A)'s allowance of the assessee's claim under section 14A read with r.w.r. 8D. The Tribunal found the AO's suo-moto disallowance unreasonable and procedurally defective because no contemporaneous satisfaction was recorded to justify overriding the assessee's self-disallowance, and the AO failed to segregate investments yielding exempt income. The AO's computation, which exceeded total P&L expenses and ignored the assessee's working confined to investments producing exempt income, was held to lack logical basis and factual appreciation. Consequently, the excess disallowance imposed by the AO was deleted and the revenue's appeal dismissed.
ITAT dismissed the revenue's appeal and upheld the CIT(A)'s allowance of the assessee's claim under section 14A read with r.w.r. 8D. The Tribunal found the AO's suo-moto disallowance unreasonable and procedurally defective because no contemporaneous satisfaction was recorded to justify overriding the assessee's self-disallowance, and the AO failed to segregate investments yielding exempt income. The AO's computation, which exceeded total P&L expenses and ignored the assessee's working confined to investments producing exempt income, was held to lack logical basis and factual appreciation. Consequently, the excess disallowance imposed by the AO was deleted and the revenue's appeal dismissed.
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