Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
Declared transaction value for direct imports of HMS scrap and other re-meltable scrap could not be rejected because the department had not shown any basis for doubt or produced contemporaneous import evidence; the re-determined value and differential duty for the 36 direct-import Bills of Entry were therefore set aside. For high sea sale imports, assessable value had to be fixed on the actual contract price subject to verification of the full document chain, including the original invoice, high sea sale contract and related charges; because documentation was incomplete for some Bills of Entry and undervaluation was admitted for seven, the valuation issue and duty liability were remanded for fresh adjudication after hearing. Penalties on the importer and co-appellants were also remanded for reconsideration in light of the fresh valuation exercise.
Declared transaction value for direct imports of HMS scrap and other re-meltable scrap could not be rejected because the department had not shown any basis for doubt or produced contemporaneous import evidence; the re-determined value and differential duty for the 36 direct-import Bills of Entry were therefore set aside. For high sea sale imports, assessable value had to be fixed on the actual contract price subject to verification of the full document chain, including the original invoice, high sea sale contract and related charges; because documentation was incomplete for some Bills of Entry and undervaluation was admitted for seven, the valuation issue and duty liability were remanded for fresh adjudication after hearing. Penalties on the importer and co-appellants were also remanded for reconsideration in light of the fresh valuation exercise.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
