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...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
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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