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...
Books of account of a project office cannot be rejected merely because no revenue was shown in the year and only expenditure was claimed; absent cogent material, such rejection is unsustainable, and the appellate deletion of its consequences was upheld. Additions made by treating a foreign exchange item as fees for technical services and by treating head office remittances as undisclosed income also failed because they were unsupported by substance or material evidence. The ITAT agreed with the Commissioner (Appeals) that the assessee's project-office receipts and remittances did not justify the impugned additions, and it dismissed the Revenue's appeal.
Books of account of a project office cannot be rejected merely because no revenue was shown in the year and only expenditure was claimed; absent cogent material, such rejection is unsustainable, and the appellate deletion of its consequences was upheld. Additions made by treating a foreign exchange item as fees for technical services and by treating head office remittances as undisclosed income also failed because they were unsupported by substance or material evidence. The ITAT agreed with the Commissioner (Appeals) that the assessee's project-office receipts and remittances did not justify the impugned additions, and it dismissed the Revenue's appeal.
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