Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Customs Broker disciplinary liability under the CBLR, 2013 was upheld for serious failures of due diligence, supervision and verification, where the evidence showed inadequate oversight of customs clearance operations and insufficient verification of exporters' credentials. The Tribunal found these lapses sufficient to establish violations of Regulations 11(a), 11(b), 11(n) and 17(9), but it did not find conclusive proof of deliberate collusion, sharing of drawback, illegal gratification or conscious participation in the alleged fraud. On that basis, forfeiture of the security deposit was sustained as a proportionate lesser penalty, revocation of licence was not ordered, and continued suspension could not be justified merely because investigation remained pending.
Customs Broker disciplinary liability under the CBLR, 2013 was upheld for serious failures of due diligence, supervision and verification, where the evidence showed inadequate oversight of customs clearance operations and insufficient verification of exporters' credentials. The Tribunal found these lapses sufficient to establish violations of Regulations 11(a), 11(b), 11(n) and 17(9), but it did not find conclusive proof of deliberate collusion, sharing of drawback, illegal gratification or conscious participation in the alleged fraud. On that basis, forfeiture of the security deposit was sustained as a proportionate lesser penalty, revocation of licence was not ordered, and continued suspension could not be justified merely because investigation remained pending.
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