Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
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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