Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
Penalty on appellant-CHA - abetting in the mis-declaration of the imported goods - the case cannot be built on the basis of vague statement of the co-accused and mere existence of call records - neither any evidence has been found during the search of the Appellant residence nor it is clear whether investigation could reach of the actual importer - penalty without properly establishing his role is not acceptable
Penalty on appellant-CHA - abetting in the mis-declaration of the imported goods - the case cannot be built on the basis of vague statement of the co-accused and mere existence of call records - neither any evidence has been found during the search of the Appellant residence nor it is clear whether investigation could reach of the actual importer - penalty without properly establishing his role is not acceptable
Note: It is a system-generated summary and is for quick reference only.