Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
The appellate tribunal held that there was no dispute regarding the transferability of the DFRC license. The appellants were unaware of the license holder after selling it, and it was the buyer's responsibility to register at the port of export and apply for Telegraphic Release Advice (TRA) as per the relevant public notice. The facts did not establish any mischief or wrongdoing by the appellants concerning the alleged change claimed by the revenue authorities. Since the appellants' role was unclear, imposing a penalty on them was not in accordance with the law. Consequently, the impugned orders were set aside, the penalty imposed on the appellants was deleted, and the appeal was allowed.
The appellate tribunal held that there was no dispute regarding the transferability of the DFRC license. The appellants were unaware of the license holder after selling it, and it was the buyer's responsibility to register at the port of export and apply for Telegraphic Release Advice (TRA) as per the relevant public notice. The facts did not establish any mischief or wrongdoing by the appellants concerning the alleged change claimed by the revenue authorities. Since the appellants' role was unclear, imposing a penalty on them was not in accordance with the law. Consequently, the impugned orders were set aside, the penalty imposed on the appellants was deleted, and the appeal was allowed.
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