Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
CESTAT appellate proceedings involving seized gold bars. Tribunal found insufficient evidence to prove foreign origin of gold, with purity ranging 995.7 to 998.9. Revenue failed to establish 'reasonable belief' of smuggling under Customs Act. Seizure deemed improper as appellant falls under Section 123(1)(a)(i) as possessor. Tribunal directed opportunity for cross-examination of initial seizure officers and remanded case for fresh adjudication, requiring Adjudicating Authority to comprehensively reassess evidence. Appeal disposed with directions to conduct detailed reexamination, potentially leading to return of seized gold to appellant.
CESTAT appellate proceedings involving seized gold bars. Tribunal found insufficient evidence to prove foreign origin of gold, with purity ranging 995.7 to 998.9. Revenue failed to establish 'reasonable belief' of smuggling under Customs Act. Seizure deemed improper as appellant falls under Section 123(1)(a)(i) as possessor. Tribunal directed opportunity for cross-examination of initial seizure officers and remanded case for fresh adjudication, requiring Adjudicating Authority to comprehensively reassess evidence. Appeal disposed with directions to conduct detailed reexamination, potentially leading to return of seized gold to appellant.
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TaxTMI 
TaxTMI 
of 4879 
