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...
Penalties for facilitating alleged fraudulent exports were held unsustainable where the Revenue failed to produce cogent, independent or corroborative evidence of the customs broker's conscious involvement in overvaluation or wrongful IGST refund claims. The Tribunal held that mere suspicion, conjecture, presumptions, or the fact that documents passed through intermediaries could not justify penal action. It followed its earlier decision on substantially similar facts and found no material distinction or contrary precedent, so the penalties under Sections 114(iii) and 114AA were set aside.
Penalties for facilitating alleged fraudulent exports were held unsustainable where the Revenue failed to produce cogent, independent or corroborative evidence of the customs broker's conscious involvement in overvaluation or wrongful IGST refund claims. The Tribunal held that mere suspicion, conjecture, presumptions, or the fact that documents passed through intermediaries could not justify penal action. It followed its earlier decision on substantially similar facts and found no material distinction or contrary precedent, so the penalties under Sections 114(iii) and 114AA were set aside.
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