Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
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...
Prolonged non-payment of import dues was treated as a deferred payment arrangement and external commercial borrowing under the RBI circulars and the Borrowing or Lending in Foreign Exchange Regulations; the absence of a formal loan agreement did not alter that character, so FEMA contravention was sustained. Post-facto RBI remittance letters were limited to foreign-exchange permission and did not condone the breach. The Tribunal also upheld liability of the directors for the company's contravention, finding no due diligence defence. It rejected the argument that absence of mens rea barred civil penalty under FEMA, though it reduced the penalties.
Prolonged non-payment of import dues was treated as a deferred payment arrangement and external commercial borrowing under the RBI circulars and the Borrowing or Lending in Foreign Exchange Regulations; the absence of a formal loan agreement did not alter that character, so FEMA contravention was sustained. Post-facto RBI remittance letters were limited to foreign-exchange permission and did not condone the breach. The Tribunal also upheld liability of the directors for the company's contravention, finding no due diligence defence. It rejected the argument that absence of mens rea barred civil penalty under FEMA, though it reduced the penalties.
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