Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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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.
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