Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Certain Export Oriented Units (EOUs) fraudulently obtained Advance Licences/Advance Release Orders (AROs) without actual manufacture or removal of excisable goods. They falsified records to show clearance of goods against these licences/AROs to fulfill export obligations, despite no physical movement of goods. The appellant, acting as an agent for purchase and sale of these licences/AROs, was not a party to the fraud committed by EOUs. Without knowledge of such fraud, the appellant cannot be penalized. The Tribunal, following its earlier decisions, set aside the penalties imposed on the appellant under relevant rules and acts for lack of culpable involvement in the fraudulent activities of EOUs.
Certain Export Oriented Units (EOUs) fraudulently obtained Advance Licences/Advance Release Orders (AROs) without actual manufacture or removal of excisable goods. They falsified records to show clearance of goods against these licences/AROs to fulfill export obligations, despite no physical movement of goods. The appellant, acting as an agent for purchase and sale of these licences/AROs, was not a party to the fraud committed by EOUs. Without knowledge of such fraud, the appellant cannot be penalized. The Tribunal, following its earlier decisions, set aside the penalties imposed on the appellant under relevant rules and acts for lack of culpable involvement in the fraudulent activities of EOUs.
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