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 ...
Disallowance of purchases under section 37 was challenged where the assessee produced invoices, bank statements showing payments through banking channels, supplier confirmations and GST returns; the Tribunal held that production of these documents discharged the assessee's primary onus and, absent affirmative contrary material from the revenue proving suppliers non-existent or payments returned as cashback, the AO/first appellate authority could not draw an adverse inference to disallow entire purchases. Reliance on precedent supporting that complete disallowance is impermissible when supporting documents are furnished; disallowance deleted.
Disallowance of purchases under section 37 was challenged where the assessee produced invoices, bank statements showing payments through banking channels, supplier confirmations and GST returns; the Tribunal held that production of these documents discharged the assessee's primary onus and, absent affirmative contrary material from the revenue proving suppliers non-existent or payments returned as cashback, the AO/first appellate authority could not draw an adverse inference to disallow entire purchases. Reliance on precedent supporting that complete disallowance is impermissible when supporting documents are furnished; disallowance deleted.
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