Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
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.
Note: It is a system-generated summary and is for quick reference only.