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...
Statutory presumption for notified gold arises only when seizure rests on reasonable belief, supported by objective material, that the particular gold was smuggled. Purity, lack of documents at interception and private carriage do not establish foreign origin. Domestic acquisition may be established through contemporaneous invoices, supplier confirmation and banking records; confiscation for breach of an import exemption condition requires identification of that breached condition. Statements recorded under customs powers remain admissible, but retracted statements require scrutiny of voluntariness, reliability and independent corroboration. Where such statements and a panchanama are challenged, denial of cross-examination of their makers materially prejudices the affected party and violates natural justice. Confiscation and related penalties were set aside, and the departmental appeal was dismissed.
Statutory presumption for notified gold arises only when seizure rests on reasonable belief, supported by objective material, that the particular gold was smuggled. Purity, lack of documents at interception and private carriage do not establish foreign origin. Domestic acquisition may be established through contemporaneous invoices, supplier confirmation and banking records; confiscation for breach of an import exemption condition requires identification of that breached condition. Statements recorded under customs powers remain admissible, but retracted statements require scrutiny of voluntariness, reliability and independent corroboration. Where such statements and a panchanama are challenged, denial of cross-examination of their makers materially prejudices the affected party and violates natural justice. Confiscation and related penalties were set aside, and the departmental appeal was dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
