Jurisdictional sanction requirements bar reassessment when approval comes from an authority lacking statutory competence under the applicable framewor...
Recorded sales receipts cannot be reassessed as unexplained cash credits, eliminating the basis for consequential alleged commission expenditure addit...
Sufficient cause for delayed income-tax appeals requires bona fide diligence; unsubstantiated counsel illness and assessee inaction defeat condonation...
TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
Rejection of declared transaction value was upheld where an interlocking body of contemporaneous private and electronic records, parallel invoices and voluntary admissions established that declared invoices omitted true consideration; such electronic records, corroborated by admissions, were admitted as probative. Given fabricated documents, clandestine payments and unreliable comparables, the Tribunal applied the residual valuation method under Rule 9 to re determine assessable value and sustained demand for differential duty with automatic interest. The Tribunal lawfully invoked extended limitation on findings of deliberate non disclosure, upheld confiscation for conscious misdeclaration with redemption option, and affirmed mandatory and personal penalties for fraud or wilful suppression on the record of admissions and corroborative documents.
Rejection of declared transaction value was upheld where an interlocking body of contemporaneous private and electronic records, parallel invoices and voluntary admissions established that declared invoices omitted true consideration; such electronic records, corroborated by admissions, were admitted as probative. Given fabricated documents, clandestine payments and unreliable comparables, the Tribunal applied the residual valuation method under Rule 9 to re determine assessable value and sustained demand for differential duty with automatic interest. The Tribunal lawfully invoked extended limitation on findings of deliberate non disclosure, upheld confiscation for conscious misdeclaration with redemption option, and affirmed mandatory and personal penalties for fraud or wilful suppression on the record of admissions and corroborative documents.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
