The ITAT determined that the assessable value under the Customs Act should not be used to justify additions under Section 69C without proof of actual expenditure.
ITAT Rules Assessable Value Under Customs Act Cannot Substitute for Expenditure Proof
The ITAT has ruled that the assessable value as prescribed under the Customs Act cannot be used to justify additions under Section 69C for unexplained expenditure without substantial proof of such expenditure.
This decision highlights the court’s stance that the mere difference between customs assessable value and invoice value does not warrant its own addition under tax assessments. Clear evidence is vital for any upward adjustment or classification to be justified.
This ruling emphasizes the importance of documentation and proof in tax assessments, providing a clearer framework for practitioners when advising clients on matters related to customs and unexplained expenditure.
Citations
- ITAT Order on Assessable Value (2026) ITAT Order
