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...
CESTAT allowed the appeal and set aside both impugned orders: the revocation of the customs broker licence, forfeiture of the security/pre-deposit and imposition of penalty were held unsustainable. The Tribunal found allegations under Regulations 10(b), 10(d), 10(m), 10(n) and 10(q) of the CBLR, 2018 unsubstantiated - noting the broker transacted at the customs station, possessed authentic exporter identifiers (IEC, GSTIN, PAN, Aadhaar), cooperated with authorities, and that no evidence showed willful alteration, delay, or lack of due diligence sufficient to merit disciplinary sanction. Consequential monetary measures were quashed and the licence revocation set aside.
CESTAT allowed the appeal and set aside both impugned orders: the revocation of the customs broker licence, forfeiture of the security/pre-deposit and imposition of penalty were held unsustainable. The Tribunal found allegations under Regulations 10(b), 10(d), 10(m), 10(n) and 10(q) of the CBLR, 2018 unsubstantiated - noting the broker transacted at the customs station, possessed authentic exporter identifiers (IEC, GSTIN, PAN, Aadhaar), cooperated with authorities, and that no evidence showed willful alteration, delay, or lack of due diligence sufficient to merit disciplinary sanction. Consequential monetary measures were quashed and the licence revocation set aside.
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