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...
Confiscation of Indian currency alleged to represent sale proceeds of smuggled gold requires the department to prove every statutory condition. The burden-of-proof presumption applies only to specified or notified goods and does not shift the burden to a person holding seized Indian currency. Confiscation further requires proof of identified smuggled goods, their sale by a person with the requisite knowledge, and a direct, identifiable nexus between that sale and the seized currency; suspicion or an unsatisfactory explanation for cash is insufficient. Penalty likewise requires identified goods liable to confiscation and proof of the relevant knowing act or dealing. Remand cannot cure missing foundational facts or expand beyond show-cause notice allegations.
Confiscation of Indian currency alleged to represent sale proceeds of smuggled gold requires the department to prove every statutory condition. The burden-of-proof presumption applies only to specified or notified goods and does not shift the burden to a person holding seized Indian currency. Confiscation further requires proof of identified smuggled goods, their sale by a person with the requisite knowledge, and a direct, identifiable nexus between that sale and the seized currency; suspicion or an unsatisfactory explanation for cash is insufficient. Penalty likewise requires identified goods liable to confiscation and proof of the relevant knowing act or dealing. Remand cannot cure missing foundational facts or expand beyond show-cause notice allegations.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
