Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
For smuggled notified gold recovered from premises under a person's possession or control, the burden shifts to that person to prove lawful import, procurement or possession. On the facts recorded, no documents or plausible explanation supported licit storage, and the surrounding circumstances independently showed keeping, harbouring and dealing with goods liable to confiscation, so liability under sections 112(a) and 112(b) was sustained. The penalty was nevertheless reduced because the seized gold lacked foreign markings and the departmental statements had not satisfied the safeguards contemplated by section 138B, making those factors relevant to quantum but not to exoneration. The appeal was partly allowed only on penalty.
For smuggled notified gold recovered from premises under a person's possession or control, the burden shifts to that person to prove lawful import, procurement or possession. On the facts recorded, no documents or plausible explanation supported licit storage, and the surrounding circumstances independently showed keeping, harbouring and dealing with goods liable to confiscation, so liability under sections 112(a) and 112(b) was sustained. The penalty was nevertheless reduced because the seized gold lacked foreign markings and the departmental statements had not satisfied the safeguards contemplated by section 138B, making those factors relevant to quantum but not to exoneration. The appeal was partly allowed only on penalty.
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