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...
Beneficial owners exercising effective control over imported goods may be treated as importers and held liable for customs duty, interest, penalty and fine, including authorised signatories acting under powers of attorney for a deceased sole proprietor. Transaction value cannot be rejected merely on NIDB data unless evidence establishes that the declared price was not the price actually paid or payable, supported by comparable-goods analysis. Where quantity misdeclaration is admitted, duty may be recovered on undeclared goods at the declared value. Findings on live consignments cannot, without proof of undervaluation, justify enhancing assessable value of past cleared consignments or confiscating them. A substantial non-bona-fide quantity discrepancy may sustain penalty under Section 114AA, although other penalty and confiscation directions may fail.
Beneficial owners exercising effective control over imported goods may be treated as importers and held liable for customs duty, interest, penalty and fine, including authorised signatories acting under powers of attorney for a deceased sole proprietor. Transaction value cannot be rejected merely on NIDB data unless evidence establishes that the declared price was not the price actually paid or payable, supported by comparable-goods analysis. Where quantity misdeclaration is admitted, duty may be recovered on undeclared goods at the declared value. Findings on live consignments cannot, without proof of undervaluation, justify enhancing assessable value of past cleared consignments or confiscating them. A substantial non-bona-fide quantity discrepancy may sustain penalty under Section 114AA, although other penalty and confiscation directions may fail.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
