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...
Levy of penalty - there is no mens rea or any premediated thought in non-complying with the statutory requirements, as no duty was actually payable upon import, being exempted goods. Thus, under the circumstances, imposition of penalty on any of the appellants would be unduly harsh and not in proportion to the nature of omission/offence particularly when no mens rea can be imputed on part of any of the parties concerned. - AT
Levy of penalty - there is no mens rea or any premediated thought in non-complying with the statutory requirements, as no duty was actually payable upon import, being exempted goods. Thus, under the circumstances, imposition of penalty on any of the appellants would be unduly harsh and not in proportion to the nature of omission/offence particularly when no mens rea can be imputed on part of any of the parties concerned. - AT
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