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 ...
Addition for alleged non genuine accommodation entries was treated as unexplained money and deleted on appeal after the appellate forum found the assessing officer's reliance on statements and investigative inputs unsustainable; the deletion was accepted by NFAC. Reopening of assessment was held invalid because the reasons relied solely on the Investigation Wing report without independent application of mind by the AO (borrowed satisfaction), so reassessment proceedings were quashed. Reopening beyond the four year period also failed because the assessee had fully and truly disclosed material facts at original assessment, negating the proviso trigger for reassessment.
Addition for alleged non genuine accommodation entries was treated as unexplained money and deleted on appeal after the appellate forum found the assessing officer's reliance on statements and investigative inputs unsustainable; the deletion was accepted by NFAC. Reopening of assessment was held invalid because the reasons relied solely on the Investigation Wing report without independent application of mind by the AO (borrowed satisfaction), so reassessment proceedings were quashed. Reopening beyond the four year period also failed because the assessee had fully and truly disclosed material facts at original assessment, negating the proviso trigger for reassessment.
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