Departmental appeal limitation after call-book recall preserves original filing, while documented correlation supports SAD refund on imported granules...
Income-tax prosecution fails when appellate remand removes its factual foundation; directors require company arraignment for vicarious criminal liabil...
Capital character of assignment consideration prevents taxation as residuary income, while unsupported interest-related expenditure remains non-deduct...
Make-available condition shields regional support-service receipts from Indian taxation where no independent capability or permanent establishment exi...
Transfer-pricing treatment of corporate guarantees and convertible loans followed prior-year consistency, with taxable foreign dividends excluded from...
Transfer-pricing benchmarking confines adjustments to associated-enterprise transactions and integrates delayed receivables through TNMM working-capit...
Voluntary statements made before Customs officers may serve as substantive evidence because Customs officers are not police officers for the statutory rule excluding police confessions. An unretracted statement, where no coercion is established and independent material corroborates its contents, may be relied upon to determine a Customs Broker's role in improper imports. Knowing advice to classify areca nuts under an incorrect tariff heading, claim an inapplicable exemption, and facilitate clearance of prohibited goods can establish abetment and justify penalties against both the Customs Broker and its director. The penalties were upheld because knowledge and intention were established through voluntary, corroborated evidence.
Voluntary statements made before Customs officers may serve as substantive evidence because Customs officers are not police officers for the statutory rule excluding police confessions. An unretracted statement, where no coercion is established and independent material corroborates its contents, may be relied upon to determine a Customs Broker's role in improper imports. Knowing advice to classify areca nuts under an incorrect tariff heading, claim an inapplicable exemption, and facilitate clearance of prohibited goods can establish abetment and justify penalties against both the Customs Broker and its director. The penalties were upheld because knowledge and intention were established through voluntary, corroborated evidence.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4886 
