Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
Retraction of confession was rejected as belated and unsupported, and the tribunal treated voluntariness and admissibility by relying on an unretracted statement that corroborated the appellant's earlier admissions; independent seizure of cash from the corroborating declarant's residence further supported the finding. The appellant failed to prove lawful import of gold. Consequentially the confiscation of the seized sum to the Central Government was upheld, while the penalty was reduced to 2,01,000 with any verified pre-deposit adjusted against the reduced penalty; the appeal was partly allowed on that basis.
Retraction of confession was rejected as belated and unsupported, and the tribunal treated voluntariness and admissibility by relying on an unretracted statement that corroborated the appellant's earlier admissions; independent seizure of cash from the corroborating declarant's residence further supported the finding. The appellant failed to prove lawful import of gold. Consequentially the confiscation of the seized sum to the Central Government was upheld, while the penalty was reduced to 2,01,000 with any verified pre-deposit adjusted against the reduced penalty; the appeal was partly allowed on that basis.
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