Minimum alternate tax exclusions for pre-amendment banking companies and expatriate Indian branch salaries remain outside head office expenditure limi...
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Consideration of transaction value and sequential redetermination under CVR rules is central, with rejection of declared value under Rule 12 followed by rules 3-9 valuation steps; the piece emphasises shifting onus and distinct burdens of proof in valuation disputes and accepts electronic records and account statements where authenticity is undisputed. It notes provisional assessments prevent attraction of penal provisions and, despite upholding assessable values after investigation and non-traversal by the importer, recommends setting aside confiscation, fines and penalties while allowing consequential relief as per law.
Consideration of transaction value and sequential redetermination under CVR rules is central, with rejection of declared value under Rule 12 followed by rules 3-9 valuation steps; the piece emphasises shifting onus and distinct burdens of proof in valuation disputes and accepts electronic records and account statements where authenticity is undisputed. It notes provisional assessments prevent attraction of penal provisions and, despite upholding assessable values after investigation and non-traversal by the importer, recommends setting aside confiscation, fines and penalties while allowing consequential relief as per law.
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