Trademark depreciation and section 14A adjustments: ITAT applies consistency, independent book-profit computation, and no disallowance without exempt ...
Rebuttable search presumptions and corroboration standards shaped deletion of unsubstantiated additions, while rental income and limited profit estima...
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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