Income-tax prosecution fails when appellate remand removes its factual foundation; directors require company arraignment for vicarious criminal liabil...
Capital character of assignment consideration prevents taxation as residuary income, while unsupported interest-related expenditure remains non-deduct...
Make-available condition shields regional support-service receipts from Indian taxation where no independent capability or permanent establishment exi...
Transfer-pricing treatment of corporate guarantees and convertible loans followed prior-year consistency, with taxable foreign dividends excluded from...
Transfer-pricing benchmarking confines adjustments to associated-enterprise transactions and integrates delayed receivables through TNMM working-capit...
Medical relief status protects government-contracted mobile healthcare from commercial classification, while provisional registration cancellation req...
Charitable registration cancellation requires proof that educational activities abandoned their objects; incidental receipts and retained surplus are ...
Prospective customs notification amendments cannot bar provisional release consideration for earlier imports when bills of lading predate their commen...
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Absolute confiscation of imported computer hard discs was set aside because the goods had already been redeemed on payment of fine and were unavailable for further redemption; the confiscation merits had attained finality. Reliance on Supreme Court precedent supporting redemption meant that a subsequent absolute-confiscation direction was non-est in law. Enhanced penalties on the importer and its business head were also set aside because the original penalties were proportionate to the offence and market value had not been determined to establish the profit margin. The adjudication order allowing redemption and imposing the original penalties was sustained.
Absolute confiscation of imported computer hard discs was set aside because the goods had already been redeemed on payment of fine and were unavailable for further redemption; the confiscation merits had attained finality. Reliance on Supreme Court precedent supporting redemption meant that a subsequent absolute-confiscation direction was non-est in law. Enhanced penalties on the importer and its business head were also set aside because the original penalties were proportionate to the offence and market value had not been determined to establish the profit margin. The adjudication order allowing redemption and imposing the original penalties was sustained.
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