Prohibited importation of cosmetics without prior regulatory registration attracts seizure and confiscation; warehousing or re export claims do not cu...
Provisional release on security permitted where cash deposit plus bond secures differential duty; classification and treaty benefits referred for deci...
Customs Valuation Rule Sequence must be followed; single-comparator re-determination and penalties set aside without comparability or proof of mis-dec...
Separately Identifiable Services: transportation found to be the essential character, so Cargo Handling classification and extended limitation rejecte...
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Whether a dependent agent constituted a permanent establishment: the tribunal examined the distribution agreement and found express clauses denying authority to bind the principal, independent purchase/resale on FOB terms, entrepreneurial, inventory and credit risk borne by the local distributor, and absence of evidence that the distributor habitually concluded contracts, maintained stock or secured orders for the foreign enterprise; therefore no Agency PE arose and attribution of 35% of offshore sales to India was rejected. Whether payments to the distributor constituted fees for technical/managerial services: the tribunal held the assessees' provision of software, web/cloud services, training and managerial support fell within "managerial/technical" services under Article 13 and sustained taxation as FTS. - ITAT
Whether a dependent agent constituted a permanent establishment: the tribunal examined the distribution agreement and found express clauses denying authority to bind the principal, independent purchase/resale on FOB terms, entrepreneurial, inventory and credit risk borne by the local distributor, and absence of evidence that the distributor habitually concluded contracts, maintained stock or secured orders for the foreign enterprise; therefore no Agency PE arose and attribution of 35% of offshore sales to India was rejected. Whether payments to the distributor constituted fees for technical/managerial services: the tribunal held the assessees' provision of software, web/cloud services, training and managerial support fell within "managerial/technical" services under Article 13 and sustained taxation as FTS. - ITAT
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