Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
Conditions for provisional release of seized imported commercial goods were held excessive once the differential duty and interest were already secured. The Tribunal noted that the goods were not prohibited and were intended for further manufacture; in one matter, a cash deposit exceeded the secured amount, and in the other, a bond for full value with bank guarantee covering the differential duty and interest had already been furnished and release had followed. It held that revenue interest stood adequately protected, so further insistence was beyond reasonable limits. The release terms were modified and release of the seized goods was directed on execution of a bond for full value.
Conditions for provisional release of seized imported commercial goods were held excessive once the differential duty and interest were already secured. The Tribunal noted that the goods were not prohibited and were intended for further manufacture; in one matter, a cash deposit exceeded the secured amount, and in the other, a bond for full value with bank guarantee covering the differential duty and interest had already been furnished and release had followed. It held that revenue interest stood adequately protected, so further insistence was beyond reasonable limits. The release terms were modified and release of the seized goods was directed on execution of a bond for full value.
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