Functional comparability under TNMM requires transaction-specific FAR analysis before benchmarking business-support services provided to associated en...
Advance pricing agreement methodology can guide benchmarking for non-covered years when functions, assets, risks and activities remain materially unch...
Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exem...
Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangemen...
Mobile-phone electronic evidence failed to establish customs undervaluation, while duty survived on non-authentic origin certificates without importer...
Automotive radio classification treats integrated infotainment features as supplementary, placing complete and qualifying unassembled units under the ...
Separate corporate personality prevents directors from being personally liable for company deposits without a guarantee or independent legal undertaki...
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Attempt to export unfinished leather in the guise of finished leather - Prohibited goods or not - After taking note of the fact that the goods have been provisionally released, re-processed and exported, it is opined that the confiscation of the goods is not warranted and justified. Accordingly, the redemption fine imposed is also to be set aside. The department has not been able to show any mens rea on the part of the appellant. - Penalty also set aside- AT
Attempt to export unfinished leather in the guise of finished leather - Prohibited goods or not - After taking note of the fact that the goods have been provisionally released, re-processed and exported, it is opined that the confiscation of the goods is not warranted and justified. Accordingly, the redemption fine imposed is also to be set aside. The department has not been able to show any mens rea on the part of the appellant. - Penalty also set aside- AT
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