Charitable sports promotion: sponsorship receipts alone did not defeat registration where funds supported tournaments and player development activitie...
Overdue associated-enterprise receivables: debt-free status defeated notional-interest adjustment, while employee stock-option costs qualified as busi...
Retrospective assessment-limitation amendments validate final orders while contemporaneous segment data governs transfer-pricing comparability and tol...
Transfer pricing adjustments must track international transactions, while unsupported AMP adjustments and unsuitable manufacturing comparables require...
Transfer-pricing adjustments must reflect functional comparability, working-capital effects, and avoid duplicating interest on associated-enterprise r...
Concurrent factual findings established that the appellant had transferred title to the imported goods and was not their owner. The goods were consigned to fictitious importing firms lacking importer-exporter codes and were routed without proper banking channels, supporting findings of systematic fraud and illegal importation. These factual findings warranted confiscation and penalty and did not raise a substantial question of law. Confiscation, refusal of re-shipment and penalty were sustained, and the customs appeal was dismissed.
Concurrent factual findings established that the appellant had transferred title to the imported goods and was not their owner. The goods were consigned to fictitious importing firms lacking importer-exporter codes and were routed without proper banking channels, supporting findings of systematic fraud and illegal importation. These factual findings warranted confiscation and penalty and did not raise a substantial question of law. Confiscation, refusal of re-shipment and penalty were sustained, and the customs appeal was dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
