Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
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No evidence showed that the customs broker knowingly participated in or abetted the attempted export of prohibited red sanders concealed in consignments declared as granite slabs. The Tribunal accepted that he had failed to verify the exporters' antecedents and had not met the due diligence and KYC standards expected under customs clearance work, so penalty was justified in principle under Section 114. As knowledge or involvement in the smuggling was not established, and the appellate record itself noted he was not involved in the nefarious activity, the penalty was found excessive and reduced to a nominal amount.
No evidence showed that the customs broker knowingly participated in or abetted the attempted export of prohibited red sanders concealed in consignments declared as granite slabs. The Tribunal accepted that he had failed to verify the exporters' antecedents and had not met the due diligence and KYC standards expected under customs clearance work, so penalty was justified in principle under Section 114. As knowledge or involvement in the smuggling was not established, and the appellate record itself noted he was not involved in the nefarious activity, the penalty was found excessive and reduced to a nominal amount.
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