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...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Absolute confiscation of gold - The case involved the confiscation of gold by customs authorities from a jeweler, who contested the allegations of smuggling and illegal importation. The appellant provided substantial evidence, including invoices and transaction records, to prove the legality of their gold procurement activities. They argued that the seized gold was domestically sourced and not of foreign origin, highlighting discrepancies in its characteristics. The Appellate Tribunal found merit in the appellant's submissions, criticizing the lower court's reliance on unsubstantiated assumptions. Consequently, the appeal was allowed, and the appellant was granted relief, including the return of seized gold or refund of auction proceeds.
Absolute confiscation of gold - The case involved the confiscation of gold by customs authorities from a jeweler, who contested the allegations of smuggling and illegal importation. The appellant provided substantial evidence, including invoices and transaction records, to prove the legality of their gold procurement activities. They argued that the seized gold was domestically sourced and not of foreign origin, highlighting discrepancies in its characteristics. The Appellate Tribunal found merit in the appellant's submissions, criticizing the lower court's reliance on unsubstantiated assumptions. Consequently, the appeal was allowed, and the appellant was granted relief, including the return of seized gold or refund of auction proceeds.
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