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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Customs penalty was unsustainable where no show cause notice was served on the appellant and he was denied a proper hearing, breaching natural justice. The Tribunal also held that personal penalties on a director could not stand without credible evidence of active role, knowledge, or a specific act or omission attracting Sections 112(a), 112(b) or 114AA. Mere association with the company was insufficient, so the penalty was set aside and the appeal allowed.
Customs penalty was unsustainable where no show cause notice was served on the appellant and he was denied a proper hearing, breaching natural justice. The Tribunal also held that personal penalties on a director could not stand without credible evidence of active role, knowledge, or a specific act or omission attracting Sections 112(a), 112(b) or 114AA. Mere association with the company was insufficient, so the penalty was set aside and the appeal allowed.
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