International transaction characterisation of domestic divestment of support services business rejected; transaction between resident associated enter...
Minimum Import Price restrictions for Black Pepper, Areca-nuts and Apples upheld; procedural laying failure not fatal, notifications to be placed befo...
Transaction value between related persons requires market-equivalent pricing; importer must prove declared value mirrors ordinary international trade ...
Classification of exported insecticides under export tariff affirmed; reclassification and related penalties set aside and MEIS scrip jurisdiction rec...
Revision under section 263 was examined regarding additions for allegedly unexplained purchases/sales and allied issues. Where the seller's sales had already been accepted/settled in first appeal, the same transactions could not be treated as unexplained in the purchaser's hands, and the revisional direction could not nullify the CIT(A)'s finding; section 263 jurisdiction was held improperly exercised to that extent. However, for purchases from another supplier whose sales were not shown to have been accepted and where the AO had made a bogus sales addition after PMGKY surrender, the AO's enquiry was held incomplete, justifying set-aside for de novo consideration. The unexplained difference between audited P&L profit and computed income also warranted de novo examination, and audit-objection-based initiation was upheld. Appeal partly allowed. - ITAT
Revision under section 263 was examined regarding additions for allegedly unexplained purchases/sales and allied issues. Where the seller's sales had already been accepted/settled in first appeal, the same transactions could not be treated as unexplained in the purchaser's hands, and the revisional direction could not nullify the CIT(A)'s finding; section 263 jurisdiction was held improperly exercised to that extent. However, for purchases from another supplier whose sales were not shown to have been accepted and where the AO had made a bogus sales addition after PMGKY surrender, the AO's enquiry was held incomplete, justifying set-aside for de novo consideration. The unexplained difference between audited P&L profit and computed income also warranted de novo examination, and audit-objection-based initiation was upheld. Appeal partly allowed. - ITAT
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