Judicial review of settlement orders cannot reopen settled customs notices, while statutory interest remains subject to verification and quantificatio...
Customs Broker licence lending for consideration justified revocation where exporter authorisation and client verification obligations were also breac...
Fraudulent import documents suspend limitation protection, while redemption of confiscated goods requires duty and interest despite bona fide purchase...
ODR arbitration participation remains mandatory after failed conciliation, while jurisdictional and maintainability objections stay available before t...
Transparency in technical bid evaluation requires disclosed standards and recorded reasons; opaque scoring invalidated tender awards and required fres...
Automated export obligation extensions remove separate regional applications after committee approval for Advance Authorisation and EPCG authorisation...
International cargo transhipment through Indian ports continues with Customs-controlled storage, re-export safeguards, and coordinated multi-station m...
Manpower support service receipts were held not taxable as fees for technical services under Article 12(4)(b) of the India-US DTAA because the services did not make available any technical knowledge, skill, know-how or process. The Tribunal followed its decision in the assessee's own preceding year, noting that the DRP had issued no fresh directions for the year under appeal and that no distinguishing material was shown. Mere facilitation of collaboration with US academic institutions was insufficient to satisfy the make available test, so the addition was deleted.
Manpower support service receipts were held not taxable as fees for technical services under Article 12(4)(b) of the India-US DTAA because the services did not make available any technical knowledge, skill, know-how or process. The Tribunal followed its decision in the assessee's own preceding year, noting that the DRP had issued no fresh directions for the year under appeal and that no distinguishing material was shown. Mere facilitation of collaboration with US academic institutions was insufficient to satisfy the make available test, so the addition was deleted.
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