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...
Voluntary statements made by an importer, its proprietor and its agents during a Customs Act inquiry may be relied on as substantive admissions where they acknowledge under-invoicing and retail sale price misdeclaration. Denial of cross-examination does not breach natural justice where those persons cannot be compelled to depose against themselves. Original supplier invoices recovered from the importer's laptop and forensically examined in its presence constitute primary electronic evidence, without requiring a certificate applicable to secondary electronic records. Evidence of misdeclaration justified rejection of the declared transaction value and sequential redetermination under the Customs Valuation Rules. The consequential duty demand, confiscation and penalties were sustained.
Voluntary statements made by an importer, its proprietor and its agents during a Customs Act inquiry may be relied on as substantive admissions where they acknowledge under-invoicing and retail sale price misdeclaration. Denial of cross-examination does not breach natural justice where those persons cannot be compelled to depose against themselves. Original supplier invoices recovered from the importer's laptop and forensically examined in its presence constitute primary electronic evidence, without requiring a certificate applicable to secondary electronic records. Evidence of misdeclaration justified rejection of the declared transaction value and sequential redetermination under the Customs Valuation Rules. The consequential duty demand, confiscation and penalties were sustained.
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