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...
Reassessment initiated under s.147 based on material emanating from a third-party search was held valid because the statutory preconditions for s.153C were not met, particularly the absence of any satisfaction note by the searched person's AO and its transmission to the assessee's AO; hence the assessee could not compel invocation of s.153C, and the AO's formation of belief was supported by fresh tangible material regarding alleged pre-arranged trades to claim s.10(38) exemption, so the jurisdictional challenge failed. On the s.68 addition treating share sale proceeds as unexplained, the matter was remanded for fresh consideration since the assessee had not discharged onus, yet certain relied-upon external data was not confronted; directions were issued to permit further evidence and require disclosure of the relied material. - ITAT
Reassessment initiated under s.147 based on material emanating from a third-party search was held valid because the statutory preconditions for s.153C were not met, particularly the absence of any satisfaction note by the searched person's AO and its transmission to the assessee's AO; hence the assessee could not compel invocation of s.153C, and the AO's formation of belief was supported by fresh tangible material regarding alleged pre-arranged trades to claim s.10(38) exemption, so the jurisdictional challenge failed. On the s.68 addition treating share sale proceeds as unexplained, the matter was remanded for fresh consideration since the assessee had not discharged onus, yet certain relied-upon external data was not confronted; directions were issued to permit further evidence and require disclosure of the relied material. - ITAT
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