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...
The High Court dismissed the appeal filed by the Customs broker challenging the revocation of license and forfeiture of security deposit by the Customs authorities. The court held that the power to suspend and revoke the license are distinct under the Customs Brokers Licensing Regulations, 2018. The 90-day timeline for initiating revocation proceedings applies from the date of the offence report, not the preliminary enquiry for suspension. Although the revocation notice was issued beyond 90 days from the preliminary enquiry, it was within the permissible period from the offence report date. The broker's consistent violations of verifying exporter details under Regulation 10(n) justified the revocation, despite the Tribunal's order being improper. No substantial question of law arose for consideration.
The High Court dismissed the appeal filed by the Customs broker challenging the revocation of license and forfeiture of security deposit by the Customs authorities. The court held that the power to suspend and revoke the license are distinct under the Customs Brokers Licensing Regulations, 2018. The 90-day timeline for initiating revocation proceedings applies from the date of the offence report, not the preliminary enquiry for suspension. Although the revocation notice was issued beyond 90 days from the preliminary enquiry, it was within the permissible period from the offence report date. The broker's consistent violations of verifying exporter details under Regulation 10(n) justified the revocation, despite the Tribunal's order being improper. No substantial question of law arose for consideration.
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