Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
Non-declared gold ornaments carried as baggage may remain liable to confiscation, but confiscability is distinct from the discretion to permit redemption on payment of fine. The note states that this discretion depends on the nature of the breach, passenger conduct and surrounding circumstances, including whether the goods are finished personal ornaments and whether carriage indicates organised smuggling. It distinguishes cases involving commercial quantities of primary gold. It also identifies absence of prior involvement, organised activity or carriage for another person as factors supporting a proportionate reduction in penalty.
Non-declared gold ornaments carried as baggage may remain liable to confiscation, but confiscability is distinct from the discretion to permit redemption on payment of fine. The note states that this discretion depends on the nature of the breach, passenger conduct and surrounding circumstances, including whether the goods are finished personal ornaments and whether carriage indicates organised smuggling. It distinguishes cases involving commercial quantities of primary gold. It also identifies absence of prior involvement, organised activity or carriage for another person as factors supporting a proportionate reduction in penalty.
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