Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Statutory presumption over seized gold under customs law arose only if the Department first established a reasonable belief at seizure, supported by objective material; suspicion, town-area recovery, purity alone, or a recital of foreign origin were insufficient. The Tribunal also held that investigation statements could not, without the safeguards required by law and independent corroboration, sustain findings of smuggling or document fabrication. Because the Revenue failed to prove smuggled origin or conscious falsity in the supporting records, the confiscation failed and the penalties for dealing with confiscable goods and for false documents were set aside.
Statutory presumption over seized gold under customs law arose only if the Department first established a reasonable belief at seizure, supported by objective material; suspicion, town-area recovery, purity alone, or a recital of foreign origin were insufficient. The Tribunal also held that investigation statements could not, without the safeguards required by law and independent corroboration, sustain findings of smuggling or document fabrication. Because the Revenue failed to prove smuggled origin or conscious falsity in the supporting records, the confiscation failed and the penalties for dealing with confiscable goods and for false documents were set aside.
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