Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
The Tribunal treated the dispute as covered by its earlier coordinate Bench ruling on similar facts involving alleged misuse of duty-free import authorisations and discharge of export obligations. Applying that precedent, it found no case for imposing penalties on the supporting manufacturer or the deemed export recipient under customs law, and upheld the order to the extent it had declined such penalties. The Revenue's challenge to non-imposition of penalties therefore failed.
The Tribunal treated the dispute as covered by its earlier coordinate Bench ruling on similar facts involving alleged misuse of duty-free import authorisations and discharge of export obligations. Applying that precedent, it found no case for imposing penalties on the supporting manufacturer or the deemed export recipient under customs law, and upheld the order to the extent it had declined such penalties. The Revenue's challenge to non-imposition of penalties therefore failed.
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