Alternative statutory remedy and unexplained delay barred writ review of customs confiscation adjudication, leaving merits for appellate consideration...
Authorised courier due diligence protects against penalties where declared exports conceal prohibited goods despite proper documentation and customs p...
Customs-controlled container movement now extends to DP World facilities, subject to segregation, inspections, reconciliation, and EXIM cargo priority...
TDS u/s 195 - Addition u/s 40(a)(i) - remittances without deducting tax at source [TAS] - disallowances qua payments made by assessee concerning purchases from its seven (07) group companies - The High court held that this aspect was concededly not the subject matter of the disallowance ordered under Section 40(a) of the Act. The disallowance under the said provision was confined to payments made by the respondent/assessee against purchases required to conform to the equal treatment clause or the non-discrimination Clause contained in Article 24(3)/26(3). Perhaps for this reason, the AO did not take recourse to the provisions of Article 9 of the respective DTAAs. - The High court found that the ITAT was correct in its interpretation of the DTAA provisions, which override domestic tax laws where more beneficial to the assessee.
TDS u/s 195 - Addition u/s 40(a)(i) - remittances without deducting tax at source [TAS] - disallowances qua payments made by assessee concerning purchases from its seven (07) group companies - The High court held that this aspect was concededly not the subject matter of the disallowance ordered under Section 40(a) of the Act. The disallowance under the said provision was confined to payments made by the respondent/assessee against purchases required to conform to the equal treatment clause or the non-discrimination Clause contained in Article 24(3)/26(3). Perhaps for this reason, the AO did not take recourse to the provisions of Article 9 of the respective DTAAs. - The High court found that the ITAT was correct in its interpretation of the DTAA provisions, which override domestic tax laws where more beneficial to the assessee.
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