Advance pricing agreement methodology can guide benchmarking for non-covered years when functions, assets, risks and activities remain materially unch...
Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exem...
Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangemen...
Mobile-phone electronic evidence failed to establish customs undervaluation, while duty survived on non-authentic origin certificates without importer...
Automotive radio classification treats integrated infotainment features as supplementary, placing complete and qualifying unassembled units under the ...
Separate corporate personality prevents directors from being personally liable for company deposits without a guarantee or independent legal undertaki...
Rule 26(2) personal penalty for invoices issued without delivery of goods requires proof that the individual issued, or abetted the issue of, such invoices. Penalty against a director was unsustainable where the company received no show-cause notice, the director was not an authorised signatory, and no finding established issuance, connivance, or abetment. Purchasers' reversal of credit did not independently establish liability. Truck-owner statements could not be relied upon without compliance with the mandatory procedure for admitting statements under section 9D. The penalty was set aside with consequential relief.
Rule 26(2) personal penalty for invoices issued without delivery of goods requires proof that the individual issued, or abetted the issue of, such invoices. Penalty against a director was unsustainable where the company received no show-cause notice, the director was not an authorised signatory, and no finding established issuance, connivance, or abetment. Purchasers' reversal of credit did not independently establish liability. Truck-owner statements could not be relied upon without compliance with the mandatory procedure for admitting statements under section 9D. The penalty was set aside with consequential relief.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
