Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
Levy of penalty u/s 117 - connivance in overvaluation of goods imported - Employees of the Customs Broker - A perusal of the impugned order does not point out as to what was expected of the present appellant, being one of innumerable employees of the Customs Broker, as his duty to comply with, which the appellant had ‘failed’ to perform. Insofar as this appellant is concerned, the Commissioner himself has observed that there was no direct evidence of connivance. - No penalty - AT
Levy of penalty u/s 117 - connivance in overvaluation of goods imported - Employees of the Customs Broker - A perusal of the impugned order does not point out as to what was expected of the present appellant, being one of innumerable employees of the Customs Broker, as his duty to comply with, which the appellant had ‘failed’ to perform. Insofar as this appellant is concerned, the Commissioner himself has observed that there was no direct evidence of connivance. - No penalty - AT
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