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 ...
Revocation of Customs Broker License - there is not even an assertion by the Revenue that on the day the Shipping Bills were filed the exporters did not exist at the premises. - The evidence available on record in the form of verification reports relied upon in the SCNs are vague and in some cases, even the name of the exporter who they were enquiring about is not indicated in them - Order of revocation, forfeiture of security deposit and penalty set aside - AT
Revocation of Customs Broker License - there is not even an assertion by the Revenue that on the day the Shipping Bills were filed the exporters did not exist at the premises. - The evidence available on record in the form of verification reports relied upon in the SCNs are vague and in some cases, even the name of the exporter who they were enquiring about is not indicated in them - Order of revocation, forfeiture of security deposit and penalty set aside - AT
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