Transfer-pricing comparability requires functional alignment; delayed associated-enterprise receivables need separate LIBOR-based benchmarking, while ...
Extended reassessment limitation in search cases requires asset-linked escaped income, invalidating additions based only on unexplained money or expen...
Enhanced tolerance band under section 43CA applies retrospectively, deleting qualifying deemed-sale additions while disputed stamp valuation requires ...
Customs transaction value rejection requires communicated reasonable doubt, while written reassessment acceptance preserves challenges to enhanced val...
Challenge-mechanism compliance clarifications permitted, while unilateral revised resolution plans may be refused under creditors' commercial discreti...
Customs valuation safeguards require the proper officer to communicate written reasons for doubting a declared transaction value and disclose relevant contemporaneous import particulars, including quantity, quality and temporal comparability. Acceptance letters given while seeking clearance on payment of duty under protest do not by themselves establish voluntary acceptance of enhanced value or waive these requirements. Written acceptance of reassessment may dispense with a speaking order, but it does not extinguish the statutory right to challenge reassessment on merits. Consent or acquiescence cannot defeat a statutory appeal; enhancement founded solely on undisclosed comparable data and acceptance letters cannot be sustained, and rejection of such appeals must be set aside with consequential relief.
Customs valuation safeguards require the proper officer to communicate written reasons for doubting a declared transaction value and disclose relevant contemporaneous import particulars, including quantity, quality and temporal comparability. Acceptance letters given while seeking clearance on payment of duty under protest do not by themselves establish voluntary acceptance of enhanced value or waive these requirements. Written acceptance of reassessment may dispense with a speaking order, but it does not extinguish the statutory right to challenge reassessment on merits. Consent or acquiescence cannot defeat a statutory appeal; enhancement founded solely on undisclosed comparable data and acceptance letters cannot be sustained, and rejection of such appeals must be set aside with consequential relief.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
