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 ...
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Whether seized documents constituted "incriminating material" to sustain an addition under section 68: Tribunal found the assessee's books and financials consistently showed investment/trading in shares, no evidence of physical movement of goods, and no AO finding that seized Tally data were parallel books; search material related to other group entities and thus irrelevant to the assessee's transactions. Legal basis: absence of incriminating material and reliance on Supreme Court precedent. Outcome: addition treating loans as bogus under section 68 is unsupported and is deleted; appeal allowed. - ITAT
Whether seized documents constituted "incriminating material" to sustain an addition under section 68: Tribunal found the assessee's books and financials consistently showed investment/trading in shares, no evidence of physical movement of goods, and no AO finding that seized Tally data were parallel books; search material related to other group entities and thus irrelevant to the assessee's transactions. Legal basis: absence of incriminating material and reliance on Supreme Court precedent. Outcome: addition treating loans as bogus under section 68 is unsupported and is deleted; appeal allowed. - ITAT
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