Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Levy of penalty - Smuggling - imitation jewellery raw material glass beads (Chatons) in the guise of clearing glass show piece/scrubbers/foot wear - In any case, it is not the case of the Department that those two persons had gained unauthorized access and that the appellant had helped in any way, in accommodating the unauthorized access or exit from the scene. - There is otherwise no allegation by the Revenue as to security and access control and therefore, the penalty cannot be sustained. - AT
Levy of penalty - Smuggling - imitation jewellery raw material glass beads (Chatons) in the guise of clearing glass show piece/scrubbers/foot wear - In any case, it is not the case of the Department that those two persons had gained unauthorized access and that the appellant had helped in any way, in accommodating the unauthorized access or exit from the scene. - There is otherwise no allegation by the Revenue as to security and access control and therefore, the penalty cannot be sustained. - AT
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