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...
Revocation of Customs Broker License - Proceedings for revocation of license contemplated under regulations 14 and 17 are independent of the proceedings for suspension of the license under regulation 16. Merely because the Commissioner of Customs decides not to continue with the suspension order after hearing the Customs Broker, would not divest the Commissioner of Customs of his power to proceed under regulations 14 and 17 for revocation of the license. - AT
Revocation of Customs Broker License - Proceedings for revocation of license contemplated under regulations 14 and 17 are independent of the proceedings for suspension of the license under regulation 16. Merely because the Commissioner of Customs decides not to continue with the suspension order after hearing the Customs Broker, would not divest the Commissioner of Customs of his power to proceed under regulations 14 and 17 for revocation of the license. - AT
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