Regulatory consolidation for investment advisers: SEBI issues master circular consolidating guidance and prescribing compliance, reporting, fees and s...
Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
Transaction value declared for imports from a related foreign principal was held to represent true assessable value because the supervisory valuation bench had concluded the relationship did not influence price; the assessing officers rejection based on later observations and selected contemporaneous third-party prices was unjustified. The tribunal found the SVB order valid for the relevant consignments, disapproved adoption of third-party contemporaneous prices where buyers and quantities differed, and accepted that price differences fell within permissible resale margins and overheads. Consequentially, the impugned re-determination of value was set aside and the appeal allowed.
Transaction value declared for imports from a related foreign principal was held to represent true assessable value because the supervisory valuation bench had concluded the relationship did not influence price; the assessing officers rejection based on later observations and selected contemporaneous third-party prices was unjustified. The tribunal found the SVB order valid for the relevant consignments, disapproved adoption of third-party contemporaneous prices where buyers and quantities differed, and accepted that price differences fell within permissible resale margins and overheads. Consequentially, the impugned re-determination of value was set aside and the appeal allowed.
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