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...
Exotic birds and mammals not being notified goods under Section 123 of the Customs Act, the burden remained on the Revenue to prove their smuggled character. The Tribunal found that the supplier's statement and the domestic supply chain explained possession, while no independent corroborative evidence showed illegal importation; mere suspicion or alleged foreign origin was insufficient. On that basis, confiscation of the seized birds and mammals was set aside, the penalty failed with the smuggling case, and the vehicle could not be confiscated once the main allegation collapsed. Release of the goods and vehicle was upheld.
Exotic birds and mammals not being notified goods under Section 123 of the Customs Act, the burden remained on the Revenue to prove their smuggled character. The Tribunal found that the supplier's statement and the domestic supply chain explained possession, while no independent corroborative evidence showed illegal importation; mere suspicion or alleged foreign origin was insufficient. On that basis, confiscation of the seized birds and mammals was set aside, the penalty failed with the smuggling case, and the vehicle could not be confiscated once the main allegation collapsed. Release of the goods and vehicle was upheld.
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