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...
Foreign exchange gain/loss treated as non-operative for assessee and comparables due to risk mitigation by associated enterprises. Safe Harbor Rules not applicable as assessee not determined eligible. Inconsistent approach by TPO in treating forex gain/loss as operating for comparables rejected. Case laws distinguishable due to risk borne by assessee. Zenith Computers excluded as persistent loss-making company. Whirlpool and Penguin excluded as functionally dissimilar from mobile phone manufacturing. For CSD segment, Infobeans Technologies, Persistent Systems, L&T Infotech, and Mindtree excluded due to functional dissimilarity or lack of segmental data. Dividend distribution tax payable at rate u/s 115O, not DTAA rate, unless DTAA expressly extends benefit to domestic company. Appeal partly allowed.
Foreign exchange gain/loss treated as non-operative for assessee and comparables due to risk mitigation by associated enterprises. Safe Harbor Rules not applicable as assessee not determined eligible. Inconsistent approach by TPO in treating forex gain/loss as operating for comparables rejected. Case laws distinguishable due to risk borne by assessee. Zenith Computers excluded as persistent loss-making company. Whirlpool and Penguin excluded as functionally dissimilar from mobile phone manufacturing. For CSD segment, Infobeans Technologies, Persistent Systems, L&T Infotech, and Mindtree excluded due to functional dissimilarity or lack of segmental data. Dividend distribution tax payable at rate u/s 115O, not DTAA rate, unless DTAA expressly extends benefit to domestic company. Appeal partly allowed.
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