Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Non-declaration of dutiable gold articles is examined through the Customs Declaration Form, contemporaneous documentary evidence and the absence of independent material supporting an alternative account. The text addresses the evidentiary effect of unavailable airport CCTV footage where it was automatically erased before preservation was sought. It also considers the reliability of a retracted statement recorded under the Customs Act, particularly where signed disclosures, a Panchnama and the lack of contemporaneous proof of coercion provide corroboration. Judicial review under Article 226 is described as limited to perversity, no evidence or manifest illegality, rather than reappreciation of plausible factual findings.
Non-declaration of dutiable gold articles is examined through the Customs Declaration Form, contemporaneous documentary evidence and the absence of independent material supporting an alternative account. The text addresses the evidentiary effect of unavailable airport CCTV footage where it was automatically erased before preservation was sought. It also considers the reliability of a retracted statement recorded under the Customs Act, particularly where signed disclosures, a Panchnama and the lack of contemporaneous proof of coercion provide corroboration. Judicial review under Article 226 is described as limited to perversity, no evidence or manifest illegality, rather than reappreciation of plausible factual findings.
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