Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
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...
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Abetment of attempted export requires a positive act supported by admissible evidence of assistance, tampering, or knowledge of concealment. The notes state that no evidence linked the exporter, its managing partner, employees, or Customs House Agent to loading red sanders into a container declared to carry roofing tiles, tampering with the container, or knowing of the concealment during transit. On that basis, penalties against the exporter-side parties were set aside, while the proposed penalty against the Customs House Agent remained dropped. A remand for fresh adjudication was considered unjustified because no aggrieved party had challenged confiscation of the goods.
Abetment of attempted export requires a positive act supported by admissible evidence of assistance, tampering, or knowledge of concealment. The notes state that no evidence linked the exporter, its managing partner, employees, or Customs House Agent to loading red sanders into a container declared to carry roofing tiles, tampering with the container, or knowing of the concealment during transit. On that basis, penalties against the exporter-side parties were set aside, while the proposed penalty against the Customs House Agent remained dropped. A remand for fresh adjudication was considered unjustified because no aggrieved party had challenged confiscation of the goods.
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