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...
Under the Customs Broker Licensing Regulations, 2018, proper client authorisation need not be received directly from the importer where authorisation letters are available. A Customs Broker is not shown to have failed in its duty to advise clients merely because inferior quality or overvaluation is detected after First Check assessment, physical examination and valuation by approved valuers, absent evidence of deficient advice. KYC obligations are met by obtaining IEC, GSTIN, PAN and other documents issued by competent authorities; the regulations do not require independent verification of every document or physical verification of the importer's premises. On these principles, alleged breaches of the authorisation, advisory and KYC duties were not established, and licence revocation and security forfeiture were set aside.
Under the Customs Broker Licensing Regulations, 2018, proper client authorisation need not be received directly from the importer where authorisation letters are available. A Customs Broker is not shown to have failed in its duty to advise clients merely because inferior quality or overvaluation is detected after First Check assessment, physical examination and valuation by approved valuers, absent evidence of deficient advice. KYC obligations are met by obtaining IEC, GSTIN, PAN and other documents issued by competent authorities; the regulations do not require independent verification of every document or physical verification of the importer's premises. On these principles, alleged breaches of the authorisation, advisory and KYC duties were not established, and licence revocation and security forfeiture were set aside.
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