Charitable sports promotion: sponsorship receipts alone did not defeat registration where funds supported tournaments and player development activitie...
Overdue associated-enterprise receivables: debt-free status defeated notional-interest adjustment, while employee stock-option costs qualified as busi...
Retrospective assessment-limitation amendments validate final orders while contemporaneous segment data governs transfer-pricing comparability and tol...
Transfer pricing adjustments must track international transactions, while unsupported AMP adjustments and unsuitable manufacturing comparables require...
Transfer-pricing adjustments must reflect functional comparability, working-capital effects, and avoid duplicating interest on associated-enterprise r...
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Penalty under Rule 26 for dealing in goods liable to confiscation requires proof that the person acquired, possessed or dealt with excisable goods knowing or believing them to be liable to confiscation. Allegations of clandestine removal require affirmative evidence across the production and supply chain, including unaccounted procurement and production, transport and clearance, identified buyers' receipt, and unaccounted consideration; recovered diaries or notepads alone do not establish their contents as true. Statements recorded during investigation may be relied on where examination and cross-examination opportunities were provided but not used, without violating natural justice.
Penalty under Rule 26 for dealing in goods liable to confiscation requires proof that the person acquired, possessed or dealt with excisable goods knowing or believing them to be liable to confiscation. Allegations of clandestine removal require affirmative evidence across the production and supply chain, including unaccounted procurement and production, transport and clearance, identified buyers' receipt, and unaccounted consideration; recovered diaries or notepads alone do not establish their contents as true. Statements recorded during investigation may be relied on where examination and cross-examination opportunities were provided but not used, without violating natural justice.
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