Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
Reverse burden of proof for notified gold is discharged when the carrier produces a delivery challan supporting lawful possession. The evidential burden then shifts to Revenue to prove foreign origin and smuggling. A town seizure, gold purity below 99.9%, and procurement records corroborated by GSTR-2A did not establish reasonable belief that the gold was smuggled. On those facts, confiscation was set aside and release of the gold was directed.
Reverse burden of proof for notified gold is discharged when the carrier produces a delivery challan supporting lawful possession. The evidential burden then shifts to Revenue to prove foreign origin and smuggling. A town seizure, gold purity below 99.9%, and procurement records corroborated by GSTR-2A did not establish reasonable belief that the gold was smuggled. On those facts, confiscation was set aside and release of the gold was directed.
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TaxTMI 
TaxTMI 
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