Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
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Customs seizure of gold bars requires objective material showing reasonable belief of smuggled or foreign origin; mere suspicion, a high purity test report, or a claimed "diamond marking" is insufficient without corroborating evidence. The text also stresses that co-noticee statements must be independently supported and properly brought on record under Section 138B before they can sustain confiscation. Penalty under Section 112(b)(i) applies only where the goods are liable to confiscation and the person knowingly dealt with them or had reason to believe they were so liable. The discussion notes that confiscation and penalties were set aside on the recorded facts.
Customs seizure of gold bars requires objective material showing reasonable belief of smuggled or foreign origin; mere suspicion, a high purity test report, or a claimed "diamond marking" is insufficient without corroborating evidence. The text also stresses that co-noticee statements must be independently supported and properly brought on record under Section 138B before they can sustain confiscation. Penalty under Section 112(b)(i) applies only where the goods are liable to confiscation and the person knowingly dealt with them or had reason to believe they were so liable. The discussion notes that confiscation and penalties were set aside on the recorded facts.
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