Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
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...
Revocation of Customs Broker License - The present proceedings suffer from the vice of biasness as well as are in violation of the principles of natural justice. Also, the show cause notice issued to this appellant is time barred and bad. Further, the present proceedings are by way of repetition of the allegations in the earlier show cause notice issued to the CB company, wherein there is no specific allegation against this appellant and he was not even a party, nor any penalty was proposed against them. - AT
Revocation of Customs Broker License - The present proceedings suffer from the vice of biasness as well as are in violation of the principles of natural justice. Also, the show cause notice issued to this appellant is time barred and bad. Further, the present proceedings are by way of repetition of the allegations in the earlier show cause notice issued to the CB company, wherein there is no specific allegation against this appellant and he was not even a party, nor any penalty was proposed against them. - AT
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