Independent show-cause notices remain separate proceedings, while customs adjudication challenges should ordinarily follow the statutory appellate rem...
Institutional incapacity in customs settlement proceedings excludes non-functional quorum periods from statutory disposal timelines, preventing automa...
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Ex parte injunction service requirements were substantially met, while civil recovery and SFIO investigation into provident fund defalcation continued...
Enforcement of resolution-plan directions continues without a Supreme Court stay, preventing suspension of redistribution and escrowed-fund distributi...
Third-party ownership claims over attached property require Special Court adjudication where purchasers lack registered sale deeds and bona fides rema...
Pure-agent reimbursements in clearing and forwarding services are excluded from taxable value when qualifying third-party payments are properly record...
Penalty levied u/s 271(1)(c) - Transfer pricing adjustment - assessee advanced interest free loan to its AE - The Tribunal noted that the assessee had disclosed all relevant particulars, including the arm's length price (ALP) of interest in the transfer pricing study report. - The Appellate Tribunal observed that the loan transaction between the assessee and its AE was indeed a matter of international transaction. However, considering the explanations provided by the assessee, including the nature of the transaction as an equity investment, the Tribunal ruled that the imposition of penalties was not warranted.
Penalty levied u/s 271(1)(c) - Transfer pricing adjustment - assessee advanced interest free loan to its AE - The Tribunal noted that the assessee had disclosed all relevant particulars, including the arm's length price (ALP) of interest in the transfer pricing study report. - The Appellate Tribunal observed that the loan transaction between the assessee and its AE was indeed a matter of international transaction. However, considering the explanations provided by the assessee, including the nature of the transaction as an equity investment, the Tribunal ruled that the imposition of penalties was not warranted.
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