Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Penalty imposed u/r 26 of Central Excise Rules 2002 set aside due to violation of principles of natural justice and lack of evidence. Department's case based solely on statements without allowing cross-examination. Rule 26 penalty requires involvement in clearance of goods liable for confiscation, which was not established against the appellants. Imposition of penalty u/r 26 unsustainable as appellants not involved in activities attracting Rule 26. Penalty on directors set aside as one director not concerned with activities at the relevant plant. Appeals of three appellants allowed, fourth appellant's appeal partly allowed.
Penalty imposed u/r 26 of Central Excise Rules 2002 set aside due to violation of principles of natural justice and lack of evidence. Department's case based solely on statements without allowing cross-examination. Rule 26 penalty requires involvement in clearance of goods liable for confiscation, which was not established against the appellants. Imposition of penalty u/r 26 unsustainable as appellants not involved in activities attracting Rule 26. Penalty on directors set aside as one director not concerned with activities at the relevant plant. Appeals of three appellants allowed, fourth appellant's appeal partly allowed.
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