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...
Best-judgment assessment of security agency service value must rest on actual, verifiable records and a rational nexus to services and consideration, rather than assumed growth or earlier peak turnover; unsupported demands require fresh determination. Receipts must be examined transaction-wise to exclude legally exempt, non-taxable and genuine reimbursable amounts, subject after amendment to pure-agent conditions. Export and SEZ exemptions require examination of transactional evidence, not rejection solely for missing documents. CENVAT credit cannot be denied merely because salary expenditure predominates; admissibility requires record-based verification. Extended limitation requires deliberate evasion and is unavailable for disclosed audited records, subject in any event to the five-year outer limit. Parallel proceedings must not produce duplicate demand or recovery; remand must exclude transactions already determined.
Best-judgment assessment of security agency service value must rest on actual, verifiable records and a rational nexus to services and consideration, rather than assumed growth or earlier peak turnover; unsupported demands require fresh determination. Receipts must be examined transaction-wise to exclude legally exempt, non-taxable and genuine reimbursable amounts, subject after amendment to pure-agent conditions. Export and SEZ exemptions require examination of transactional evidence, not rejection solely for missing documents. CENVAT credit cannot be denied merely because salary expenditure predominates; admissibility requires record-based verification. Extended limitation requires deliberate evasion and is unavailable for disclosed audited records, subject in any event to the five-year outer limit. Parallel proceedings must not produce duplicate demand or recovery; remand must exclude transactions already determined.
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