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...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Revocation of CHA License - Customs Broker resorted to unprofessional methods while clearing the goods imported vide Bill of Entry - It was revealed during the investigation that an employee of the appellant's office had manipulated the redemption fine and penalty amounts in the Order-in-Original, leading to the overcharging of the importer. - While the tribunal acknowledged the manipulation in the Order-in-Original, the crux of the decision rested on procedural irregularities rather than the merits of the fabrication allegations. - The tribunal ruled in favor of the appellant, emphasizing the importance of adherence to procedural timelines outlined in Regulation 20 of CBLR, 2013. It noted that the absence of a specific offence report and the delay in issuing the Show Cause Notice beyond the prescribed period rendered the proceedings against the appellant invalid.
Revocation of CHA License - Customs Broker resorted to unprofessional methods while clearing the goods imported vide Bill of Entry - It was revealed during the investigation that an employee of the appellant's office had manipulated the redemption fine and penalty amounts in the Order-in-Original, leading to the overcharging of the importer. - While the tribunal acknowledged the manipulation in the Order-in-Original, the crux of the decision rested on procedural irregularities rather than the merits of the fabrication allegations. - The tribunal ruled in favor of the appellant, emphasizing the importance of adherence to procedural timelines outlined in Regulation 20 of CBLR, 2013. It noted that the absence of a specific offence report and the delay in issuing the Show Cause Notice beyond the prescribed period rendered the proceedings against the appellant invalid.
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