Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
Scientific Research approval for Sikshya O Anusandhan under section 35(1)(ii) granted subject to reporting, certification, and compliance requirements...
Retraction of confession was rejected as belated and unsupported, and the tribunal treated voluntariness and admissibility by relying on an unretracted statement that corroborated the appellant's earlier admissions; independent seizure of cash from the corroborating declarant's residence further supported the finding. The appellant failed to prove lawful import of gold. Consequentially the confiscation of the seized sum to the Central Government was upheld, while the penalty was reduced to 2,01,000 with any verified pre-deposit adjusted against the reduced penalty; the appeal was partly allowed on that basis.
Retraction of confession was rejected as belated and unsupported, and the tribunal treated voluntariness and admissibility by relying on an unretracted statement that corroborated the appellant's earlier admissions; independent seizure of cash from the corroborating declarant's residence further supported the finding. The appellant failed to prove lawful import of gold. Consequentially the confiscation of the seized sum to the Central Government was upheld, while the penalty was reduced to 2,01,000 with any verified pre-deposit adjusted against the reduced penalty; the appeal was partly allowed on that basis.
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