Transition support services from corporate spinoff for India business segment - TP adjustment deleted; comparables reassessed; goodwill depreciation, ...
Qualification of fire extinguishers as aircraft parts - original duty finding under Notification No.50/2017-Sr.545 vacated; remanded for fresh adjudic...
An inchoate agreement to sell, lacking execution by both parties and showing patent ambiguity, could not be treated as conclusive evidence of receipt of unaccounted on-money. The Tribunal held that an admission must be clear, unambiguous and unconditional, and that the seized document, without material particulars such as witness details or the drafter's identity and without the beneficiary's participation, did not justify an inference of undisclosed cash receipts. The additions based on that document were therefore deleted, and the consequential penalty was also deleted.
An inchoate agreement to sell, lacking execution by both parties and showing patent ambiguity, could not be treated as conclusive evidence of receipt of unaccounted on-money. The Tribunal held that an admission must be clear, unambiguous and unconditional, and that the seized document, without material particulars such as witness details or the drafter's identity and without the beneficiary's participation, did not justify an inference of undisclosed cash receipts. The additions based on that document were therefore deleted, and the consequential penalty was also deleted.
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