The Court: Affidavit of service filed today be kept with the record.
We have heard learned advocates on either side.
The appeal is admitted on the following substantial questions of law for
consideration.
“i. Whether the Learned Tribunal committed substantial error in law
in treating the difference between the import value declared by the
assessee and the value estimated by the Customs Authority as
unexplained expenditure under section 69C of the Income-tax Act,
1961 in the absence of any evidence of actual expenditure ?
ii. Whether the Learned Tribunal erred in law in holding that the
assessable value determined under the Customs Valuation
(Determination of Value of Imported Goods) Rules, 2007 for the
purpose of levy of customs duty constitutes the actual purchase
price paid by the importer for the purposes of the Income-tax Act,
1961 ?
