Modified returns after business reorganisations cannot trigger fresh scrutiny once the original assessment was complete, invalidating related transfer...
Third-party loose sheets require reliable nexus before supporting unexplained expenditure additions; presumptions do not establish payer identity or o...
TNMM comparability using audited accounts and working-capital adjustments can eliminate unwarranted transfer-pricing additions where verified margins ...
Gross-profit additions on disputed purchases require reasoned appellate determination; disclosed claims alone do not support inaccurate-particulars pe...
Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barr...
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursement...
Palmolein classification defeated the crude-oil concession; material misdeclaration sustained recovery and confiscation, while separate false-document...
Written acceptance of an enhanced customs assessable value does not waive an importer's statutory right to challenge reassessment; it may only dispense with the proper officer's obligation to issue a speaking order. Rule 12(2) requires the proper officer to form and communicate written grounds for reasonable doubt before rejecting the declared transaction value. Acceptance letters lacking particulars of alleged contemporaneous imports do not meet that requirement. NIDB data alone, without independent and cogent supporting material, cannot sustain rejection of declared value or enhancement. The enhanced values and appellate orders were unsustainable, and the appeals succeeded with consequential relief.
Written acceptance of an enhanced customs assessable value does not waive an importer's statutory right to challenge reassessment; it may only dispense with the proper officer's obligation to issue a speaking order. Rule 12(2) requires the proper officer to form and communicate written grounds for reasonable doubt before rejecting the declared transaction value. Acceptance letters lacking particulars of alleged contemporaneous imports do not meet that requirement. NIDB data alone, without independent and cogent supporting material, cannot sustain rejection of declared value or enhancement. The enhanced values and appellate orders were unsustainable, and the appeals succeeded with consequential relief.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
