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...
Medical relief status protects government-contracted mobile healthcare from commercial classification, while provisional registration cancellation req...
Charitable registration cancellation requires proof that educational activities abandoned their objects; incidental receipts and retained surplus are ...
Prospective customs notification amendments cannot bar provisional release consideration for earlier imports when bills of lading predate their commen...
Target Plus Scheme requires a broad nexus, not a strict product-to-product nexus, between duty-free imported inputs and exports within the product group specified in the duty credit certificate. Continuous cast copper rods could therefore be imported duty-free where linked to the Engineering Products group, but not merely because they bore nexus to one of several groups covered by a certificate. Extended limitation and customs penalties require intent to evade duty through fraud, collusion, wilful misstatement or suppression. Policy ambiguity, a bona fide exemption understanding, valid uncancelled certificates, and export documents already held in Customs records precluded such findings. The duty demand and consequential penalties were set aside.
Target Plus Scheme requires a broad nexus, not a strict product-to-product nexus, between duty-free imported inputs and exports within the product group specified in the duty credit certificate. Continuous cast copper rods could therefore be imported duty-free where linked to the Engineering Products group, but not merely because they bore nexus to one of several groups covered by a certificate. Extended limitation and customs penalties require intent to evade duty through fraud, collusion, wilful misstatement or suppression. Policy ambiguity, a bona fide exemption understanding, valid uncancelled certificates, and export documents already held in Customs records precluded such findings. The duty demand and consequential penalties were set aside.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
