Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
A claim of forged Chartered Accountant certificates in a non-resident to resident share transfer failed because the appellant relied only on an uncorroborated denial and produced no independent proof of forgery. The Tribunal noted that the required documents had been routed through the authorised dealer bank, the transaction had been reported, and other material, including a later Chartered Accountant certificate and an invoice linked to the certificates, supported the respondents' version. In the absence of a police complaint or other corroborative evidence, mere suspicion was insufficient to displace the documentary record or establish contravention of the applicable FEMA and RBI transfer and pricing requirements. The appeal was dismissed and the respondents' exoneration was upheld.
A claim of forged Chartered Accountant certificates in a non-resident to resident share transfer failed because the appellant relied only on an uncorroborated denial and produced no independent proof of forgery. The Tribunal noted that the required documents had been routed through the authorised dealer bank, the transaction had been reported, and other material, including a later Chartered Accountant certificate and an invoice linked to the certificates, supported the respondents' version. In the absence of a police complaint or other corroborative evidence, mere suspicion was insufficient to displace the documentary record or establish contravention of the applicable FEMA and RBI transfer and pricing requirements. The appeal was dismissed and the respondents' exoneration was upheld.
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