Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
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A director's personal penalty liability was sustained where his conscious participation in undervaluation and use of dual invoices culminated in import clearance in India, giving the offence a direct territorial nexus with India. The Tribunal held that customs penal provisions could apply notwithstanding that some acts originated outside India, because the fraudulent importation was completed in India and his liability was independent of any separate action against the foreign company. Penalty under section 112(a) was upheld on evidence of deliberate involvement in the undervaluation mechanism, and penalty under section 114AA was also sustained because false invoices were knowingly prepared and used for customs transactions.
A director's personal penalty liability was sustained where his conscious participation in undervaluation and use of dual invoices culminated in import clearance in India, giving the offence a direct territorial nexus with India. The Tribunal held that customs penal provisions could apply notwithstanding that some acts originated outside India, because the fraudulent importation was completed in India and his liability was independent of any separate action against the foreign company. Penalty under section 112(a) was upheld on evidence of deliberate involvement in the undervaluation mechanism, and penalty under section 114AA was also sustained because false invoices were knowingly prepared and used for customs transactions.
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