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...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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No penalty was sustained against a Customs Broker for alleged movement of imported goods before out-of-charge because the vehicles carrying the goods remained within the Land Customs Station and were available for drawal of samples by DRI. On that factual basis, the alleged breach of permitting movement without out-of-charge was not made out. The Tribunal also noted that the appellant had already been discharged in the CBLR proceedings, making the impugned penalty unwarranted. The penalties were set aside and the appeals were allowed.
No penalty was sustained against a Customs Broker for alleged movement of imported goods before out-of-charge because the vehicles carrying the goods remained within the Land Customs Station and were available for drawal of samples by DRI. On that factual basis, the alleged breach of permitting movement without out-of-charge was not made out. The Tribunal also noted that the appellant had already been discharged in the CBLR proceedings, making the impugned penalty unwarranted. The penalties were set aside and the appeals were allowed.
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