Tax deduction compliance and payee income recognition govern consultancy disallowance, while no exempt income prevents related expenditure disallowanc...
Derivative abetment liability fails when correctly declared imported components establish no underlying improper importation by the principal importer...
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Abetment under Section 112(a) failed because abetment requires an actual committer and an abettor, and the record did not establish who the importer was or that either appellant was the importer. The Tribunal also noted that the case rested mainly on an uncorroborated statement retracted at the earliest opportunity, while a key investigative lead from the phone number in the shipping documents was not pursued; the penalty under Section 112(a) was set aside. Section 114AA was confined to fraudulent exports made only on paper without any physical export, so it did not apply to imports; the penalty under that provision was also set aside.
Abetment under Section 112(a) failed because abetment requires an actual committer and an abettor, and the record did not establish who the importer was or that either appellant was the importer. The Tribunal also noted that the case rested mainly on an uncorroborated statement retracted at the earliest opportunity, while a key investigative lead from the phone number in the shipping documents was not pursued; the penalty under Section 112(a) was set aside. Section 114AA was confined to fraudulent exports made only on paper without any physical export, so it did not apply to imports; the penalty under that provision was also set aside.
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