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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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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