Transfer-pricing comparability requires material turnover effects; adjustments must cover only associated-enterprise transactions and exclude abnormal...
Commodity derivatives position limits adopt revised breach penalties, broad commodity criteria, and client open-position limits based on deliverable s...
Independent corroboration was required to sustain a penalty for alleged involvement in an attempted export of prohibited red sanders where the allegation rested solely on statements later retracted. Retraction placed on record required consideration, and an uncorroborated retracted statement could not alone establish liability. The setting aside of penalty against the person alleged to have introduced the employee to the purported mastermind also removed the factual basis for penalising the employee. The penalty was therefore unsustainable and the appeal succeeded.
Independent corroboration was required to sustain a penalty for alleged involvement in an attempted export of prohibited red sanders where the allegation rested solely on statements later retracted. Retraction placed on record required consideration, and an uncorroborated retracted statement could not alone establish liability. The setting aside of penalty against the person alleged to have introduced the employee to the purported mastermind also removed the factual basis for penalising the employee. The penalty was therefore unsustainable and the appeal succeeded.
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TaxTMI 
TaxTMI 
of 4884 
