Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
The HC allowed the petition, holding that the impugned withdrawal of Petitioner No.1's Customs Broker Licence was unlawful and procedurally impermissible. The court found Petitioner No.2, a director of Petitioner No.1, had satisfied Regulation 6/7 of the Customs Brokers Licensing Regulations, 2018 by clearing the prescribed examinations, thereby fulfilling statutory eligibility for a Form-B2 licence. The respondents' public notice amounted in substance to revocation without invoking the Regulation 17 procedure for revocation or penalty under Regulation 14, rendering the withdrawal ultra vires. The HC quashed and set aside the withdrawal/notice and directed that the licence be treated as valid in accordance with the Regulations.
The HC allowed the petition, holding that the impugned withdrawal of Petitioner No.1's Customs Broker Licence was unlawful and procedurally impermissible. The court found Petitioner No.2, a director of Petitioner No.1, had satisfied Regulation 6/7 of the Customs Brokers Licensing Regulations, 2018 by clearing the prescribed examinations, thereby fulfilling statutory eligibility for a Form-B2 licence. The respondents' public notice amounted in substance to revocation without invoking the Regulation 17 procedure for revocation or penalty under Regulation 14, rendering the withdrawal ultra vires. The HC quashed and set aside the withdrawal/notice and directed that the licence be treated as valid in accordance with the Regulations.
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