Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
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...
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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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