Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
Corporate guarantee furnished to an associated enterprise for credit facilities was treated as an international transaction because the statutory explanation to section 92B covers capital financing, including guarantees, and the guarantee had a direct bearing on the enterprise's financial position; the transfer pricing challenge on that point failed. For arm's length commission, the Tribunal held that the guarantee exposure changed during the year as the underlying loan was repaid, so the risk assumed could not be measured only by the year-end balance. It sustained computation of commission at 0.50% on the average of opening and closing outstanding exposure, and dismissed the appeals.
Corporate guarantee furnished to an associated enterprise for credit facilities was treated as an international transaction because the statutory explanation to section 92B covers capital financing, including guarantees, and the guarantee had a direct bearing on the enterprise's financial position; the transfer pricing challenge on that point failed. For arm's length commission, the Tribunal held that the guarantee exposure changed during the year as the underlying loan was repaid, so the risk assumed could not be measured only by the year-end balance. It sustained computation of commission at 0.50% on the average of opening and closing outstanding exposure, and dismissed the appeals.
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