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 - Since, the employee of Team Logistics is not an employee of the Customs Broker, the Appellant cannot be held responsible for the misdeclaration if any, on the part of employee of Team Logistics or the Importer. Thus, the allegation in the Notice that the Appellant failed to exercise proper control over his employees, is not proved and hence the allegation in the Notice about the contravention of Rule 13 ( 12) by the Customs Broker is not sustainable. - AT
Revocation of Customs Broker License - Since, the employee of Team Logistics is not an employee of the Customs Broker, the Appellant cannot be held responsible for the misdeclaration if any, on the part of employee of Team Logistics or the Importer. Thus, the allegation in the Notice that the Appellant failed to exercise proper control over his employees, is not proved and hence the allegation in the Notice about the contravention of Rule 13 ( 12) by the Customs Broker is not sustainable. - AT
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