Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Levy of penalty u/s 112(a) and 114AA of the Customs Act - detention of yacht - suspicion of foul play - evasion of Customs Duty - The initial burden to prove proper importation, under Section 123 ibid. was on the notices, some of whom have accepted the liability and thereby resulting in the non-discharge of the burden. The natural consequence which flows from the above is that the burden cast on the notices remained un-discharged and hence, they have to suffer consequence, namely the penalties in this case. This is because, they have all been identified to be part of different sides but of the same transaction. - AT
Levy of penalty u/s 112(a) and 114AA of the Customs Act - detention of yacht - suspicion of foul play - evasion of Customs Duty - The initial burden to prove proper importation, under Section 123 ibid. was on the notices, some of whom have accepted the liability and thereby resulting in the non-discharge of the burden. The natural consequence which flows from the above is that the burden cast on the notices remained un-discharged and hence, they have to suffer consequence, namely the penalties in this case. This is because, they have all been identified to be part of different sides but of the same transaction. - AT
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