Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
Validity of suspension of a customs broker licence was assessed under the Customs Broker Licensing Regulations. Tribunal held the statutory conditions for suspension were satisfied because an inquiry was contemplated and the suspension predated or occurred during inquiry, so suspension complied with the rule for immediate action; continuation after a hearing complied with procedural requirement and recorded reasons satisfied internal instructions, resulting in upholding the suspension and dismissal of the appeal. Findings also addressed customs broker duties, due diligence failures, mis-declaration, supervision and vicarious liability for employee acts, noted as bases for disciplinary proceedings.
Validity of suspension of a customs broker licence was assessed under the Customs Broker Licensing Regulations. Tribunal held the statutory conditions for suspension were satisfied because an inquiry was contemplated and the suspension predated or occurred during inquiry, so suspension complied with the rule for immediate action; continuation after a hearing complied with procedural requirement and recorded reasons satisfied internal instructions, resulting in upholding the suspension and dismissal of the appeal. Findings also addressed customs broker duties, due diligence failures, mis-declaration, supervision and vicarious liability for employee acts, noted as bases for disciplinary proceedings.
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