Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
Scientific Research approval for Sikshya O Anusandhan under section 35(1)(ii) granted subject to reporting, certification, and compliance requirements...
Valuation by check-post authorities under Sections 129/130 cannot determine tax liability; such valuation is reserved to the jurisdictional Assessing Authority, and interception/confiscation proceedings at transit check posts must refer valuation disputes to that authority, resulting here in refusal to uphold valuation-based seizures. Non-compliance with Rule 138C's contemporaneous online inspection report (Form A) requirement vitiated the detention/confiscation basis and warranted interlocutory release of goods and detained vehicles. Sampling must be redone: samples drawn in triplicate, sealed and countersigned with petitioners or representatives, with one part forwarded to the jurisdictional Assessing Officer who may proceed with assessment.
Valuation by check-post authorities under Sections 129/130 cannot determine tax liability; such valuation is reserved to the jurisdictional Assessing Authority, and interception/confiscation proceedings at transit check posts must refer valuation disputes to that authority, resulting here in refusal to uphold valuation-based seizures. Non-compliance with Rule 138C's contemporaneous online inspection report (Form A) requirement vitiated the detention/confiscation basis and warranted interlocutory release of goods and detained vehicles. Sampling must be redone: samples drawn in triplicate, sealed and countersigned with petitioners or representatives, with one part forwarded to the jurisdictional Assessing Officer who may proceed with assessment.
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