Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Customs clearance facilitator liability for differential duty requires foundational proof that the facilitator acted with express or implied authority from the owner or importer, or knowingly participated in misdeclaration or smuggling. Filing a Bill of Entry, paying assessed duty, and arranging examination and clearance do not by themselves establish ownership, beneficial ownership, agency authority, or knowledge of concealed goods. Liability for differential duty and interest was therefore set aside. Penalty for duty evasion cannot survive without established duty liability arising from collusion, wilful misstatement, or suppression. Penalty for false customs documents also requires proof of knowing or intentional use; false documents alone are insufficient. The penalties were set aside as against the facilitator.
Customs clearance facilitator liability for differential duty requires foundational proof that the facilitator acted with express or implied authority from the owner or importer, or knowingly participated in misdeclaration or smuggling. Filing a Bill of Entry, paying assessed duty, and arranging examination and clearance do not by themselves establish ownership, beneficial ownership, agency authority, or knowledge of concealed goods. Liability for differential duty and interest was therefore set aside. Penalty for duty evasion cannot survive without established duty liability arising from collusion, wilful misstatement, or suppression. Penalty for false customs documents also requires proof of knowing or intentional use; false documents alone are insufficient. The penalties were set aside as against the facilitator.
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