Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Section 112A penalty for abetment of improper import requires evidence that the Customs Broker's G Card holder participated in, omitted an act connected with, or knowingly facilitated conduct rendering goods liable to confiscation. The note addresses an alleged import of prohibited crackers concealed as glassware, where the G Card holder returned the documents after detecting a description mismatch and informed Customs. Initial processing of Bills of Entry and personal-bank-account deposits, without further evidence of knowledge or involvement, did not establish abetment. The reported penalty was therefore set aside.
Section 112A penalty for abetment of improper import requires evidence that the Customs Broker's G Card holder participated in, omitted an act connected with, or knowingly facilitated conduct rendering goods liable to confiscation. The note addresses an alleged import of prohibited crackers concealed as glassware, where the G Card holder returned the documents after detecting a description mismatch and informed Customs. Initial processing of Bills of Entry and personal-bank-account deposits, without further evidence of knowledge or involvement, did not establish abetment. The reported penalty was therefore set aside.
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