Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Revocation of Customs Broker License - forfeiture of security deposit - levy of penalty - The CESTAT held that the appellant was responsible for the actions of their employee, as per Regulation 13(12) of the Customs Broker Licensing Regulations, 2018. Despite the appellant's claim of ignorance, the CESTAT found that they failed to exercise proper supervision over their employees and were therefore liable for the violations. - The Tribunal found that the appellant had violated several regulations, including failing to advise the client to comply with regulations, exercising due diligence, and verifying the correctness of import-export codes. The court upheld the decision of the Commissioner to revoke the appellant's license and impose penalties.
Revocation of Customs Broker License - forfeiture of security deposit - levy of penalty - The CESTAT held that the appellant was responsible for the actions of their employee, as per Regulation 13(12) of the Customs Broker Licensing Regulations, 2018. Despite the appellant's claim of ignorance, the CESTAT found that they failed to exercise proper supervision over their employees and were therefore liable for the violations. - The Tribunal found that the appellant had violated several regulations, including failing to advise the client to comply with regulations, exercising due diligence, and verifying the correctness of import-export codes. The court upheld the decision of the Commissioner to revoke the appellant's license and impose penalties.
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