Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Electronic evidence from a mobile phone was rejected because the statutory requirements for admissibility under Section 138C were not shown to be met, and the retrieved note did not match the import documents in specification or quantity. Comparable import data was also found insufficient because similarity in grade, dimensions, width and commercial level was not established, so rejection of the declared transaction value failed and undervaluation was not proved. The Tribunal further held that suppression was not made out where the show cause case rested on documents already supplied at import, making the extended period unavailable and the penalties unsustainable. Classification was left open.
Electronic evidence from a mobile phone was rejected because the statutory requirements for admissibility under Section 138C were not shown to be met, and the retrieved note did not match the import documents in specification or quantity. Comparable import data was also found insufficient because similarity in grade, dimensions, width and commercial level was not established, so rejection of the declared transaction value failed and undervaluation was not proved. The Tribunal further held that suppression was not made out where the show cause case rested on documents already supplied at import, making the extended period unavailable and the penalties unsustainable. Classification was left open.
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