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...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
Misdeclaration of goods was established and the broker breached the duty to advise the client and to intimate Customs under Regulation 13(d); that failure is a serious lapse. When management became aware of the discrepancy, vicarious liability arose under Regulation 19(8) because the manager did not ensure escalation to the licence holder and onward to Customs. No violation of Regulation 13(o) was proved. Penalty should be limited to proven breaches and cancellation of the customs broker licence was not warranted.
Misdeclaration of goods was established and the broker breached the duty to advise the client and to intimate Customs under Regulation 13(d); that failure is a serious lapse. When management became aware of the discrepancy, vicarious liability arose under Regulation 19(8) because the manager did not ensure escalation to the licence holder and onward to Customs. No violation of Regulation 13(o) was proved. Penalty should be limited to proven breaches and cancellation of the customs broker licence was not warranted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4921 
