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...
In corporate assessments of unexplained share capital and share premium, documented traceability via ITR acknowledgments, PAN details and bank statements through legitimate channels is accorded greater evidentiary weight than the Assessing Officer's subjective "Test of Human Probability"; accordingly the addition was deleted. The ratio in NRA Iron & Steel is confined to phantom or nonexistent subscribers that cannot be traced; it does not apply where subscribers are verifiable and creditworthy. Revenue must prove a direct "live link" showing funds originated from the assessee's own coffers; absent contrary material, Tribunal factual findings upholding castiron documentary evidence prevail and no substantial question of law arises.
In corporate assessments of unexplained share capital and share premium, documented traceability via ITR acknowledgments, PAN details and bank statements through legitimate channels is accorded greater evidentiary weight than the Assessing Officer's subjective "Test of Human Probability"; accordingly the addition was deleted. The ratio in NRA Iron & Steel is confined to phantom or nonexistent subscribers that cannot be traced; it does not apply where subscribers are verifiable and creditworthy. Revenue must prove a direct "live link" showing funds originated from the assessee's own coffers; absent contrary material, Tribunal factual findings upholding castiron documentary evidence prevail and no substantial question of law arises.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4813 
Join Channel 
