Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
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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