Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
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Levy of penalty u/s 112(a)/112(b)/114A/114AA of Customs Act - Smuggling - Gold Bars - Baggage Rules - Here in the case on hand, some of the officials are not even put on SCN, a few of the persons and some officials who were put on notice have been exonerated, crucial witnesses were not examined/questioned, nothing is forthcoming as to the fate of letter found and seized from Mr. Haris and hence, there are too many loose ends perhaps due to lack of proper investigation - there are no other sustainable evidence against any of the appellants and hence, the revenue has not made out any case against them. Consequently, penalty levied against them cannot be sustained. - AT
Levy of penalty u/s 112(a)/112(b)/114A/114AA of Customs Act - Smuggling - Gold Bars - Baggage Rules - Here in the case on hand, some of the officials are not even put on SCN, a few of the persons and some officials who were put on notice have been exonerated, crucial witnesses were not examined/questioned, nothing is forthcoming as to the fate of letter found and seized from Mr. Haris and hence, there are too many loose ends perhaps due to lack of proper investigation - there are no other sustainable evidence against any of the appellants and hence, the revenue has not made out any case against them. Consequently, penalty levied against them cannot be sustained. - AT
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