Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
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Violation of Regulation 10(d) of CBLR established - appellant obligated to advise client about authorization requirement for SCOMET item export, instead filed Shipping Bill. Appellant's reliance on client's declaration unacceptable - onus on appellant to know law. SCN not time-barred - issued within 80 days of receipt of correct offence report. Revocation of license, forfeiture of security deposit disproportionate considering no evidence of profiting, appellant out of work for a year. Penalty of Rs. 50,000/- upheld, revocation and forfeiture set aside. Appeal partly allowed.
Violation of Regulation 10(d) of CBLR established - appellant obligated to advise client about authorization requirement for SCOMET item export, instead filed Shipping Bill. Appellant's reliance on client's declaration unacceptable - onus on appellant to know law. SCN not time-barred - issued within 80 days of receipt of correct offence report. Revocation of license, forfeiture of security deposit disproportionate considering no evidence of profiting, appellant out of work for a year. Penalty of Rs. 50,000/- upheld, revocation and forfeiture set aside. Appeal partly allowed.
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