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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Penal liability of a Customs Broker for abetment of attempted Red Sanders export requires evidence of a positive act, prior knowledge, active collusion, or assistance; failure alone to verify an IEC holder does not establish abetment. Where the Broker obtained and verified KYC and IEC documents, co-operated with the investigation, and no evidence linked it to the attempted smuggling, the Tribunal found no basis for an abetment penalty. The penalty was set aside, and the Revenue's attempt to impose an additional penalty was rejected.
Penal liability of a Customs Broker for abetment of attempted Red Sanders export requires evidence of a positive act, prior knowledge, active collusion, or assistance; failure alone to verify an IEC holder does not establish abetment. Where the Broker obtained and verified KYC and IEC documents, co-operated with the investigation, and no evidence linked it to the attempted smuggling, the Tribunal found no basis for an abetment penalty. The penalty was set aside, and the Revenue's attempt to impose an additional penalty was rejected.
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