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...
Foreign-currency loan interest must be benchmarked against the relevant currency's LIBOR-based rate, not domestic lending rates; the interest adjustment was deleted. Corporate guarantees were treated as international transactions, but commission was restricted to 0.50% of outstanding guarantees. For section 10A, separately claimed units require factual examination as independent undertakings, while exclusions from export turnover must also be excluded from total turnover. Exempt-income disallowance excludes interest where interest-free funds exceed investments, with administrative expenditure limited to investments yielding exempt income. Hedging losses on export-related forward contracts were treated as non-speculative revenue losses. Several issues, including BPO benchmarking, software licences, creditor balances, TDS credit, surplus-fund income and foreign tax credit, required verification or fresh examination.
Foreign-currency loan interest must be benchmarked against the relevant currency's LIBOR-based rate, not domestic lending rates; the interest adjustment was deleted. Corporate guarantees were treated as international transactions, but commission was restricted to 0.50% of outstanding guarantees. For section 10A, separately claimed units require factual examination as independent undertakings, while exclusions from export turnover must also be excluded from total turnover. Exempt-income disallowance excludes interest where interest-free funds exceed investments, with administrative expenditure limited to investments yielding exempt income. Hedging losses on export-related forward contracts were treated as non-speculative revenue losses. Several issues, including BPO benchmarking, software licences, creditor balances, TDS credit, surplus-fund income and foreign tax credit, required verification or fresh examination.
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