Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
Goods seized under the Customs Act remain within the statutory confiscation and penalty adjudication framework where prior sanction has not been obtained and cognizance of a Customs offence has not been taken. The proper officer's special power to grant provisional release pending adjudication cannot be displaced through the general criminal-law power to release property on zimma. Consequently, a Sessions Court lacks jurisdiction to order release of seized areca nuts on zimma in those circumstances, and the release order was set aside.
Goods seized under the Customs Act remain within the statutory confiscation and penalty adjudication framework where prior sanction has not been obtained and cognizance of a Customs offence has not been taken. The proper officer's special power to grant provisional release pending adjudication cannot be displaced through the general criminal-law power to release property on zimma. Consequently, a Sessions Court lacks jurisdiction to order release of seized areca nuts on zimma in those circumstances, and the release order was set aside.
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