Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Customs penalty was unsustainable where no show cause notice was served on the appellant and he was denied a proper hearing, breaching natural justice. The Tribunal also held that personal penalties on a director could not stand without credible evidence of active role, knowledge, or a specific act or omission attracting Sections 112(a), 112(b) or 114AA. Mere association with the company was insufficient, so the penalty was set aside and the appeal allowed.
Customs penalty was unsustainable where no show cause notice was served on the appellant and he was denied a proper hearing, breaching natural justice. The Tribunal also held that personal penalties on a director could not stand without credible evidence of active role, knowledge, or a specific act or omission attracting Sections 112(a), 112(b) or 114AA. Mere association with the company was insufficient, so the penalty was set aside and the appeal allowed.
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