Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Levy of penalty - Smuggling of Gold - seizure - Commissioner (Appels) set aside the penalty - The Tribunal found insufficient evidence to establish the Respondents ownership. Statements of key witnesses lacked consistency, and procedural irregularities in the examination of witnesses weakened the case. Therefore, the court upheld the impugned order, dismissing the Revenue's appeal and maintaining the decision to set aside the penalty on the Respondents.
Levy of penalty - Smuggling of Gold - seizure - Commissioner (Appels) set aside the penalty - The Tribunal found insufficient evidence to establish the Respondents ownership. Statements of key witnesses lacked consistency, and procedural irregularities in the examination of witnesses weakened the case. Therefore, the court upheld the impugned order, dismissing the Revenue's appeal and maintaining the decision to set aside the penalty on the Respondents.
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