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...
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CESTAT adjudicated a customs seizure case involving gold bars transported between cities. The tribunal found the seizure invalid due to lack of substantive evidence. Key determinations included: (1) the primary statement constituted hearsay testimony, (2) no corroborative documentation established smuggling, and (3) the revenue authority failed to demonstrate reasonable belief under Section 110 of the Customs Act. The tribunal rejected revenue's arguments regarding tax invoice dates and procedural objections. Consequently, the tribunal sustained the Commissioner (Appeals) order, dismissing the revenue's appeal and nullifying the original confiscation and penalty orders against the individual.
CESTAT adjudicated a customs seizure case involving gold bars transported between cities. The tribunal found the seizure invalid due to lack of substantive evidence. Key determinations included: (1) the primary statement constituted hearsay testimony, (2) no corroborative documentation established smuggling, and (3) the revenue authority failed to demonstrate reasonable belief under Section 110 of the Customs Act. The tribunal rejected revenue's arguments regarding tax invoice dates and procedural objections. Consequently, the tribunal sustained the Commissioner (Appeals) order, dismissing the revenue's appeal and nullifying the original confiscation and penalty orders against the individual.
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