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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Departmental knowledge of identical imports and prior acceptance of the declared classification negated suppression and intent to evade duty; the extended-period duty demand and related interest were therefore set aside. Woven warp cut-pile fabrics were correctly classified under CTH 5801 because that specific heading for woven pile fabrics prevailed over general silk or rayon fabric headings, irrespective of rayon predominance. Exemptions not claimed at clearance may be claimed at adjudication, absent fraud, if substantive and procedural conditions are met; the alternative CVD and SAD claims require fresh merits determination, with any duty and interest confined to the normal period. Prior departmental acceptance also excluded deliberate misclassification, preventing confiscation and penalties.
Departmental knowledge of identical imports and prior acceptance of the declared classification negated suppression and intent to evade duty; the extended-period duty demand and related interest were therefore set aside. Woven warp cut-pile fabrics were correctly classified under CTH 5801 because that specific heading for woven pile fabrics prevailed over general silk or rayon fabric headings, irrespective of rayon predominance. Exemptions not claimed at clearance may be claimed at adjudication, absent fraud, if substantive and procedural conditions are met; the alternative CVD and SAD claims require fresh merits determination, with any duty and interest confined to the normal period. Prior departmental acceptance also excluded deliberate misclassification, preventing confiscation and penalties.
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