Independent show-cause notices remain separate proceedings, while customs adjudication challenges should ordinarily follow the statutory appellate rem...
Institutional incapacity in customs settlement proceedings excludes non-functional quorum periods from statutory disposal timelines, preventing automa...
Interactive touchscreen panels with integrated computing functions fall under automatic data-processing machines rather than display monitors for cust...
Ex parte injunction service requirements were substantially met, while civil recovery and SFIO investigation into provident fund defalcation continued...
Recovery of market data charges for third-party database access was held not taxable as royalty under Article 12 of the India-USA DTAA, because the facts matched earlier years and pendency of further appeals was not a valid reason to ignore binding coordinate bench decisions. Reimbursements of seconded employee-related expenses were also held not taxable as Fees for Included Services or Fees for Technical Services, as earlier coordinate bench rulings and a High Court dismissal had already taken the same view and no factual distinction was shown. Both substantive additions were directed to be deleted.
Recovery of market data charges for third-party database access was held not taxable as royalty under Article 12 of the India-USA DTAA, because the facts matched earlier years and pendency of further appeals was not a valid reason to ignore binding coordinate bench decisions. Reimbursements of seconded employee-related expenses were also held not taxable as Fees for Included Services or Fees for Technical Services, as earlier coordinate bench rulings and a High Court dismissal had already taken the same view and no factual distinction was shown. Both substantive additions were directed to be deleted.
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