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 ...
Classification of exported insecticides under export tariff affirmed; reclassification and related penalties set aside and MEIS scrip jurisdiction rec...
Seized marketing 'welcome letters' and loose undated digital sheets were held insufficiently reliable to support additions for alleged suppression of sales absent signatures, buyer confirmations, bank-trace or other corroboration; extrapolation of undeclared sales by applying unauthenticated online portal asking rates was held speculative and inadmissible without seized evidence, buyer examination, comparable deeds or valuation; for unexplained cash credits the assessee discharged primary onus by producing identity, ledger entries, bank records and lender financials and repayments, and the AO failed to rebut with cogent material; approval by the range head for assessment proceedings was found to be non-mechanical. Operative effect: document-based and extrapolated additions and unexplained-loan additions were deleted, while approval validity was upheld.
Seized marketing 'welcome letters' and loose undated digital sheets were held insufficiently reliable to support additions for alleged suppression of sales absent signatures, buyer confirmations, bank-trace or other corroboration; extrapolation of undeclared sales by applying unauthenticated online portal asking rates was held speculative and inadmissible without seized evidence, buyer examination, comparable deeds or valuation; for unexplained cash credits the assessee discharged primary onus by producing identity, ledger entries, bank records and lender financials and repayments, and the AO failed to rebut with cogent material; approval by the range head for assessment proceedings was found to be non-mechanical. Operative effect: document-based and extrapolated additions and unexplained-loan additions were deleted, while approval validity was upheld.
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