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...
Penal liability of a Customs Broker for abetment of attempted Red Sanders export requires evidence of a positive act, prior knowledge, active collusion, or assistance; failure alone to verify an IEC holder does not establish abetment. Where the Broker obtained and verified KYC and IEC documents, co-operated with the investigation, and no evidence linked it to the attempted smuggling, the Tribunal found no basis for an abetment penalty. The penalty was set aside, and the Revenue's attempt to impose an additional penalty was rejected.
Penal liability of a Customs Broker for abetment of attempted Red Sanders export requires evidence of a positive act, prior knowledge, active collusion, or assistance; failure alone to verify an IEC holder does not establish abetment. Where the Broker obtained and verified KYC and IEC documents, co-operated with the investigation, and no evidence linked it to the attempted smuggling, the Tribunal found no basis for an abetment penalty. The penalty was set aside, and the Revenue's attempt to impose an additional penalty was rejected.
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