Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Revocation of Customs Broker license - The Tribunal found no evidence of a direct violation by the appellants in terms of authorization processes as the appellants did receive documents from a third party, which was not prohibited. The Tribunal observed that the appellants could not have been expected to advise compliance about illegal activities they were not aware of, thus dismissing this charge. Based on these findings, the Tribunal concluded that there was no sufficient basis for the revocation of the license or the forfeiture of the security deposit for alleged violations of Regulations 10(a), 10(d), and 10(m). However, they deemed a minor penalty appropriate for the partial non-compliance with Regulation 10(n).
Revocation of Customs Broker license - The Tribunal found no evidence of a direct violation by the appellants in terms of authorization processes as the appellants did receive documents from a third party, which was not prohibited. The Tribunal observed that the appellants could not have been expected to advise compliance about illegal activities they were not aware of, thus dismissing this charge. Based on these findings, the Tribunal concluded that there was no sufficient basis for the revocation of the license or the forfeiture of the security deposit for alleged violations of Regulations 10(a), 10(d), and 10(m). However, they deemed a minor penalty appropriate for the partial non-compliance with Regulation 10(n).
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