Time limits for search-based assessments are a self-contained code; extension applies only with a transfer pricing reference, otherwise late orders ar...
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.
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