SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
Abetment of attempted export of prohibited goods requires material proving a Customs Broker's knowledge, conscious involvement or collusion. Filing shipping bills, arranging containers and processing exporter-provided documents, without more, do not establish knowing assistance; a due-diligence duty does not remove that evidentiary requirement. Failure to ascertain the meat's procurement source alone was insufficient, so the penalty was set aside. Article 226 jurisdiction was exercised despite an alternative statutory appeal because the abetment finding lacked evidentiary support, and the writ petition was entertained.
Abetment of attempted export of prohibited goods requires material proving a Customs Broker's knowledge, conscious involvement or collusion. Filing shipping bills, arranging containers and processing exporter-provided documents, without more, do not establish knowing assistance; a due-diligence duty does not remove that evidentiary requirement. Failure to ascertain the meat's procurement source alone was insufficient, so the penalty was set aside. Article 226 jurisdiction was exercised despite an alternative statutory appeal because the abetment finding lacked evidentiary support, and the writ petition was entertained.
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