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 ...
Assessment of income on account of unsubstantiated purchases was affirmed where the assessee failed to produce parties, documents or reconcile sundry balances; the tribunal upheld CIT(A)/NFAC direction to adopt a reasonable profit rate (informed by but not applying section 44AD) instead of disallowing all purchases. Separately, disallowance under the TDS provision was sustained because audited accounts and auditor silence did not excuse the assessee's statutory failure to deduct tax at source.
Assessment of income on account of unsubstantiated purchases was affirmed where the assessee failed to produce parties, documents or reconcile sundry balances; the tribunal upheld CIT(A)/NFAC direction to adopt a reasonable profit rate (informed by but not applying section 44AD) instead of disallowing all purchases. Separately, disallowance under the TDS provision was sustained because audited accounts and auditor silence did not excuse the assessee's statutory failure to deduct tax at source.
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