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...
Customs broker - Revocation of License - forfeiture of security deposit - Penalty - The Tribunal found that the appellant had indeed acted casually and allowed his license to be used by others for financial benefits, which was confirmed by his own admissions in the statement dated 04.04.2022. The Tribunal noted that such behavior breached the trust reposed in the customs broker by the department and the regulations designed to safeguard the customs procedures. The Tribunal upheld the revocation of the license and the forfeiture of the security deposit. However penalty amount received from 50K to 10K.
Customs broker - Revocation of License - forfeiture of security deposit - Penalty - The Tribunal found that the appellant had indeed acted casually and allowed his license to be used by others for financial benefits, which was confirmed by his own admissions in the statement dated 04.04.2022. The Tribunal noted that such behavior breached the trust reposed in the customs broker by the department and the regulations designed to safeguard the customs procedures. The Tribunal upheld the revocation of the license and the forfeiture of the security deposit. However penalty amount received from 50K to 10K.
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