Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
Non-fulfilment of export obligation under Advance Authorization by importer company. Penalty imposed on directors solely based on their shareholding and directorship, without establishing their role in the alleged offence. Separate proceedings already initiated against the company for duty-free import and non-fulfilment. Penalty u/s 112(a) and (b) of Customs Act imposed together, legally unsustainable. Ingredients for imposing penalty u/s 112 not existing. Penalties on directors set aside by Appellate Tribunal as unsustainable.
Non-fulfilment of export obligation under Advance Authorization by importer company. Penalty imposed on directors solely based on their shareholding and directorship, without establishing their role in the alleged offence. Separate proceedings already initiated against the company for duty-free import and non-fulfilment. Penalty u/s 112(a) and (b) of Customs Act imposed together, legally unsustainable. Ingredients for imposing penalty u/s 112 not existing. Penalties on directors set aside by Appellate Tribunal as unsustainable.
Note: It is a system-generated summary and is for quick reference only.