Constitutional personal-liberty safeguards limit PMLA twin bail conditions where completed investigations lead to prolonged incarceration before trial...
Automated airline software subscriptions without human intervention fail technical-services characterisation and do not make available underlying tech...
Business support recruitment and training receipts qualify for presumptive business taxation, not professional taxation under technical consultancy ru...
Treaty exemption for foreign permanent-establishment management fees prevailed, while dividend expense disallowance remained limited to an accepted al...
Centralised assessment transfers: participation after requesting centralisation can bar technical jurisdictional challenges, while assessment disputes...
Binding precedent remains operative despite pending challenge, supporting deletion of interest disallowance when debt is converted into preference sha...
Penal liability of a Customs Broker for abetment of attempted Red Sanders export requires evidence of a positive act, prior knowledge, active collusion, or assistance; failure alone to verify an IEC holder does not establish abetment. Where the Broker obtained and verified KYC and IEC documents, co-operated with the investigation, and no evidence linked it to the attempted smuggling, the Tribunal found no basis for an abetment penalty. The penalty was set aside, and the Revenue's attempt to impose an additional penalty was rejected.
Penal liability of a Customs Broker for abetment of attempted Red Sanders export requires evidence of a positive act, prior knowledge, active collusion, or assistance; failure alone to verify an IEC holder does not establish abetment. Where the Broker obtained and verified KYC and IEC documents, co-operated with the investigation, and no evidence linked it to the attempted smuggling, the Tribunal found no basis for an abetment penalty. The penalty was set aside, and the Revenue's attempt to impose an additional penalty was rejected.
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