Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
The impact of imposing penalty and purpose of reduced penalty not fulfilled - deterring the appellant from repeating the offence - Continued violation of policy conditions - The Tribunal in the earlier cases had reduced the redemption fine and personal penalty by 90%. - It is noticed from the pattern of continuing violation that the redemption fine and penalty imposed earlier are not discouraging the repeat of offence. It is seen that the appellants continue to violate the import policy in respect of Minimum Import Price with impunity. - AT
The impact of imposing penalty and purpose of reduced penalty not fulfilled - deterring the appellant from repeating the offence - Continued violation of policy conditions - The Tribunal in the earlier cases had reduced the redemption fine and personal penalty by 90%. - It is noticed from the pattern of continuing violation that the redemption fine and penalty imposed earlier are not discouraging the repeat of offence. It is seen that the appellants continue to violate the import policy in respect of Minimum Import Price with impunity. - AT
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