Regulatory consolidation for investment advisers: SEBI issues master circular consolidating guidance and prescribing compliance, reporting, fees and s...
Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
Where an importer receives the show cause notice and relied-upon documents but files no reply, does not attend personal hearing, and seeks adjudication on the basis of available records, the adjudicating authority may rely on the admissions already made. The appellant only objected to inclusion of inland haulage charges, and that objection was accepted; the remaining allegations on undervaluation and redetermination of transaction value were not contested. The Tribunal upheld the Commissioner (Appeals), applying the rule that admitted facts need not be proved, and found no basis to reopen the merits. The appeal was dismissed.
Where an importer receives the show cause notice and relied-upon documents but files no reply, does not attend personal hearing, and seeks adjudication on the basis of available records, the adjudicating authority may rely on the admissions already made. The appellant only objected to inclusion of inland haulage charges, and that objection was accepted; the remaining allegations on undervaluation and redetermination of transaction value were not contested. The Tribunal upheld the Commissioner (Appeals), applying the rule that admitted facts need not be proved, and found no basis to reopen the merits. The appeal was dismissed.
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