Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Turnover mismatches under percentage-completion accounting cannot alone establish suppressed income where customer advances remain recorded as liabili...
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Non-Vessel Operating Common Carriers acting as Customs Cargo Service Providers must waive detention and demurrage charges on goods seized by Customs under HCCAR. The sixty-day allowance for container detention where goods are detained for verification under SCMTR does not override that prohibition. Failure to implement a customs waiver certificate breaches applicable SCMTR obligations and can support immediate suspension of NVOCC registration. Post-decisional opportunity to make representations may satisfy natural justice following such immediate suspension.
Non-Vessel Operating Common Carriers acting as Customs Cargo Service Providers must waive detention and demurrage charges on goods seized by Customs under HCCAR. The sixty-day allowance for container detention where goods are detained for verification under SCMTR does not override that prohibition. Failure to implement a customs waiver certificate breaches applicable SCMTR obligations and can support immediate suspension of NVOCC registration. Post-decisional opportunity to make representations may satisfy natural justice following such immediate suspension.
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