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 ...
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Under the faceless assessment framework, specialized units (Assessment, Verification, Technical, Review) must conduct or procure factual verification when complex technical claims arise. The Principal Commissioner found the assessment silent on actuarial valuation of post employment benefit remeasurement, payments vis a vis tax deductibility rules, and adjustments for realized foreign exchange gains to capital assets, with no Verification Unit report or recorded enquiries. That absence amounted to a lack of enquiry rather than mere inadequate enquiry; consequence: the assessment was set aside and the Assessing Officer directed to carry out proper verification and pass a fresh order after allowing the taxpayer opportunity to be heard.
Under the faceless assessment framework, specialized units (Assessment, Verification, Technical, Review) must conduct or procure factual verification when complex technical claims arise. The Principal Commissioner found the assessment silent on actuarial valuation of post employment benefit remeasurement, payments vis a vis tax deductibility rules, and adjustments for realized foreign exchange gains to capital assets, with no Verification Unit report or recorded enquiries. That absence amounted to a lack of enquiry rather than mere inadequate enquiry; consequence: the assessment was set aside and the Assessing Officer directed to carry out proper verification and pass a fresh order after allowing the taxpayer opportunity to be heard.
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