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...
Whether income could be extrapolated from a list of purported employees found during a survey: the Tribunal held that additions must be confined to incriminating material seized during survey and cannot be extrapolated without independent corroboration; reliance on precedent rejecting extrapolation further supports this reasoning, therefore extrapolation across months was unsustainable and disallowed. Consequence: the addition is restricted to Rs. 2,54,115 as per the seized document, taxed under section 69C read with section 115BBE; appeal partly allowed. - ITAT
Whether income could be extrapolated from a list of purported employees found during a survey: the Tribunal held that additions must be confined to incriminating material seized during survey and cannot be extrapolated without independent corroboration; reliance on precedent rejecting extrapolation further supports this reasoning, therefore extrapolation across months was unsustainable and disallowed. Consequence: the addition is restricted to Rs. 2,54,115 as per the seized document, taxed under section 69C read with section 115BBE; appeal partly allowed. - ITAT
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