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 u/r 26 - Personal penalty for abatement in evasion of duty - a plain reading of Rule 26 indicates that imposition of the penalty therein is not tied to a condition that excisable goods have to be placed under confiscation under the Act/Rules - Only, the person implicated/concerned should have the knowledge of “possible confiscation” of the impugned goods. From the facts on record, the appellant have played crucial role in commission of offence by the manufacturer. Appellant is liable to penalty under Rule 26 of the Central Excise Rules.- AT
Levy of penalty u/r 26 - Personal penalty for abatement in evasion of duty - a plain reading of Rule 26 indicates that imposition of the penalty therein is not tied to a condition that excisable goods have to be placed under confiscation under the Act/Rules - Only, the person implicated/concerned should have the knowledge of “possible confiscation” of the impugned goods. From the facts on record, the appellant have played crucial role in commission of offence by the manufacturer. Appellant is liable to penalty under Rule 26 of the Central Excise Rules.- AT
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