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...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
Redemption of confiscated prohibited foreign currency is discretionary, but the discretion must be exercised judiciously on the facts rather than rejected mechanically because the currency is prohibited. Where no material establishes a previous violation and the imposed penalty has been paid, refusal to permit redemption requires reconsideration. Redemption fine must remain within the statutory ceiling and follow principles governing release of confiscated foreign currency. The refusal of release was set aside, with redemption fine to be determined according to law and the currency released upon payment.
Redemption of confiscated prohibited foreign currency is discretionary, but the discretion must be exercised judiciously on the facts rather than rejected mechanically because the currency is prohibited. Where no material establishes a previous violation and the imposed penalty has been paid, refusal to permit redemption requires reconsideration. Redemption fine must remain within the statutory ceiling and follow principles governing release of confiscated foreign currency. The refusal of release was set aside, with redemption fine to be determined according to law and the currency released upon payment.
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