Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Denial of cross-examination in customs broker licence proceedings breached procedural fairness because the regulation entitled the broker to cross-examine persons examined in support of the charges, and any refusal had to be recorded with written reasons. Where the show cause notice relied on a witness statement to frame the charges and no cross-examination was allowed despite a written request, the proceedings were vitiated. The Revenue's arguments on deemed revocation and non-appearance at personal hearings were not considered, and the issue of a fresh show cause notice after earlier revocation was left open for an appropriate case. The Revenue's appeal was dismissed.
Denial of cross-examination in customs broker licence proceedings breached procedural fairness because the regulation entitled the broker to cross-examine persons examined in support of the charges, and any refusal had to be recorded with written reasons. Where the show cause notice relied on a witness statement to frame the charges and no cross-examination was allowed despite a written request, the proceedings were vitiated. The Revenue's arguments on deemed revocation and non-appearance at personal hearings were not considered, and the issue of a fresh show cause notice after earlier revocation was left open for an appropriate case. The Revenue's appeal was dismissed.
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