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 ...
Protective additions based on seized books were set aside where corresponding substantive assessments against a third party were quashed for lack of jurisdiction and the assessing authorities had not independently examined seized material or the assessee's statements; matters remitted to the AO for fresh adjudication. The limitation challenge failed because contemporaneous records showed exchange-of-information references bringing Explanation 1(x) to section 153 into play, so the assessment was within the extended period. Approval under section 153D was held administrative; absence of elaborate reasons did not rebut the presumption of application of mind. Telescoping of admitted undisclosed income against seized cash was permitted, and complex quantification issues were remitted for recomputation with opportunity to the assessee.
Protective additions based on seized books were set aside where corresponding substantive assessments against a third party were quashed for lack of jurisdiction and the assessing authorities had not independently examined seized material or the assessee's statements; matters remitted to the AO for fresh adjudication. The limitation challenge failed because contemporaneous records showed exchange-of-information references bringing Explanation 1(x) to section 153 into play, so the assessment was within the extended period. Approval under section 153D was held administrative; absence of elaborate reasons did not rebut the presumption of application of mind. Telescoping of admitted undisclosed income against seized cash was permitted, and complex quantification issues were remitted for recomputation with opportunity to the assessee.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4816 
Join Channel 
