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...
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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