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...
Levy of penalty u/s 112(a) - under-invoicing the import goods - Power of DRI to issue SCN - In the present case, the order was adjudicated by the Joint Commissioner of Customs and there is no dispute that he had the jurisdiction to adjudicate the question of levy of penalty under Section 122 of the Customs Act - the question as to whether the officers of DRI are proper officers for issuance of notice u/s 28 of the Customs Act does not arise in the present case. - HC
Levy of penalty u/s 112(a) - under-invoicing the import goods - Power of DRI to issue SCN - In the present case, the order was adjudicated by the Joint Commissioner of Customs and there is no dispute that he had the jurisdiction to adjudicate the question of levy of penalty under Section 122 of the Customs Act - the question as to whether the officers of DRI are proper officers for issuance of notice u/s 28 of the Customs Act does not arise in the present case. - HC
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