https://www.taxtmi.com/caselaws?id=11920 The HC held that once imports are from persons covered by section 40A(2)(b) the burden lies on the assessee to prove prices are not excessive or unreasonable. The assessee failed to produce an affidavit or evidence showing fair market pricing for purchases from its foreign sister concern, and authorities below erred in merely relying on prior-year decisions. Noting unexplained cost differentials between related-party and third-party purchases, the HC set aside earlier orders and remitted the matter to the AO to reassess the disallowance under section 40A(2)(b) after permitting evidence and cross-examination. en-us Wed, 29 Jan 2003 00:00:00 +0530 Mon, 29 Sep 2025 16:10:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=11920 The HC held that once imports are from persons covered by section 40A(2)(b) the burden lies on the assessee to prove prices are not excessive or unreasonable. The assessee failed to produce an affidavit or evidence showing fair market pricing for purchases from its foreign sister concern, and authorities below erred in merely relying on prior-year decisions. Noting unexplained cost differentials between related-party and third-party purchases, the HC set aside earlier orders and remitted the matter to the AO to reassess the disallowance under section 40A(2)(b) after permitting evidence and cross-examination. Case-Laws Income Tax Wed, 29 Jan 2003 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=11920