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...
Invocation of jurisdiction under section 153C based solely on electronic material seized from third-party premises was held invalid because the seized account books contained no indicia linking them to the assessee; statutory presumptions operate in favour of the searched person and were not rebutted. Entries in third-party private notings were treated as "dumb documents" absent independent, corroborative evidence tying them to the assessee, and witness retraction undermined testimonial support. Consequently the AO's satisfaction under section 153C was held to be without jurisdiction and the assessment order was quashed.
Invocation of jurisdiction under section 153C based solely on electronic material seized from third-party premises was held invalid because the seized account books contained no indicia linking them to the assessee; statutory presumptions operate in favour of the searched person and were not rebutted. Entries in third-party private notings were treated as "dumb documents" absent independent, corroborative evidence tying them to the assessee, and witness retraction undermined testimonial support. Consequently the AO's satisfaction under section 153C was held to be without jurisdiction and the assessment order was quashed.
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