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 ...
Reliance on hypothecation statement to determine taxable income was upheld where the hypothecation statement recorded quantities and values, was certified as reflecting books of account, and showed substantial unexplained discrepancies with bank records; the AO's notional addition was justified because inflated stock declarations to secure higher bank credit constituted commercially immoral conduct and admissible material. On appellate review, the HC found the Tribunal's affirmation rested on proper appreciation of the record and was neither perverse nor unsupported by evidence, therefore appellate interference was unwarranted and the addition sustained.
Reliance on hypothecation statement to determine taxable income was upheld where the hypothecation statement recorded quantities and values, was certified as reflecting books of account, and showed substantial unexplained discrepancies with bank records; the AO's notional addition was justified because inflated stock declarations to secure higher bank credit constituted commercially immoral conduct and admissible material. On appellate review, the HC found the Tribunal's affirmation rested on proper appreciation of the record and was neither perverse nor unsupported by evidence, therefore appellate interference was unwarranted and the addition sustained.
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