Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
Penalty against a customs broker failed where the import dispute was treated as an interpretational classification issue and the importer had already been exonerated for absence of mala fide intent. On those facts, a broker who merely filed Bills of Entry on the importer's instructions could not be said to have abetted evasion, and the ingredients for penalty based on false declaration were not made out. The Tribunal also held that the objection on invocation of the larger period would apply equally to the appellants. The penalties under Sections 112(a) and 114AA were deleted and the appeals were allowed.
Penalty against a customs broker failed where the import dispute was treated as an interpretational classification issue and the importer had already been exonerated for absence of mala fide intent. On those facts, a broker who merely filed Bills of Entry on the importer's instructions could not be said to have abetted evasion, and the ingredients for penalty based on false declaration were not made out. The Tribunal also held that the objection on invocation of the larger period would apply equally to the appellants. The penalties under Sections 112(a) and 114AA were deleted and the appeals were allowed.
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