Customs Valuation Rule Sequence must be followed; single-comparator re-determination and penalties set aside without comparability or proof of mis-dec...
Separately Identifiable Services: transportation found to be the essential character, so Cargo Handling classification and extended limitation rejecte...
Assessment under section 153C was held time-barred because, in a joint warrant situation, limitation under section 153B had to be computed with reference to the last panchanama in the assessee's own case; the later panchanama of another person could not extend time, and the assessments were quashed. Jurisdiction under section 153C also failed because the satisfaction note was generic and did not record year-wise nexus between seized material and alleged undisclosed income, making the assumption of jurisdiction invalid. The addition for alleged commission income was deleted because it rested only on uncorroborated third-party statements, with no independent incriminating material and no cross-examination opportunity.
Assessment under section 153C was held time-barred because, in a joint warrant situation, limitation under section 153B had to be computed with reference to the last panchanama in the assessee's own case; the later panchanama of another person could not extend time, and the assessments were quashed. Jurisdiction under section 153C also failed because the satisfaction note was generic and did not record year-wise nexus between seized material and alleged undisclosed income, making the assumption of jurisdiction invalid. The addition for alleged commission income was deleted because it rested only on uncorroborated third-party statements, with no independent incriminating material and no cross-examination opportunity.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4809 
Join Channel 
