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...
Revocation of customs broker license challenged due to lack of specific allegations in show cause notice regarding violations of Regulations 11(n) and 17(9) of 2013 Customs Brokers Licensing Regulations. Show cause notice merely reproduced Additional Commissioner's order without detailing reasons for alleged violations. Commissioner's order found deficient as it did not consider broker's reply and based findings solely on Additional Commissioner's order. Tribunal held show cause notice defective for not spelling out specific charges, rendering Commissioner's order unsustainable on grounds of violation of principles of natural justice. Order set aside for lack of proper opportunity to broker to defend charges.
Revocation of customs broker license challenged due to lack of specific allegations in show cause notice regarding violations of Regulations 11(n) and 17(9) of 2013 Customs Brokers Licensing Regulations. Show cause notice merely reproduced Additional Commissioner's order without detailing reasons for alleged violations. Commissioner's order found deficient as it did not consider broker's reply and based findings solely on Additional Commissioner's order. Tribunal held show cause notice defective for not spelling out specific charges, rendering Commissioner's order unsustainable on grounds of violation of principles of natural justice. Order set aside for lack of proper opportunity to broker to defend charges.
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