Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
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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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