Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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Gold, a notified item under Section 123 of the Customs Act, was recovered from an appellant's personal possession and from concealment in a car; the claim of licit acquisition required the claimants to discharge the statutory reverse burden. As the appellants failed to prove lawful import/possession and relied on belated documents and retraction of statements, the gold was held to be smuggled and liable to confiscation under Section 111, resulting in upholding of absolute confiscation. Their knowing involvement in handling, transportation, and possession justified penalties under Section 112(b); the penalties were held reasonable and not liable to interference. Appeal dismissed - CESTAT
Gold, a notified item under Section 123 of the Customs Act, was recovered from an appellant's personal possession and from concealment in a car; the claim of licit acquisition required the claimants to discharge the statutory reverse burden. As the appellants failed to prove lawful import/possession and relied on belated documents and retraction of statements, the gold was held to be smuggled and liable to confiscation under Section 111, resulting in upholding of absolute confiscation. Their knowing involvement in handling, transportation, and possession justified penalties under Section 112(b); the penalties were held reasonable and not liable to interference. Appeal dismissed - CESTAT
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