Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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Decision addresses revocation of a customs broker licence and penalty under the Customs Brokers Licensing Regulations for failure to advise a passenger and report non-compliance when an official email showed a consignment contained other passengers' baggage, constituting breach of the broker's duty to inform. The tribunal found provisions on client identification and valuation inapplicable where the passenger was personally present and where valuation was not within the broker's authority. Fraud by an employee outside authority did not attract company liability. Electronic email evidence was treated as decisive and unrefuted, licence revocation and security forfeiture were set aside, but a monetary penalty was confirmed for the duty breach.
Decision addresses revocation of a customs broker licence and penalty under the Customs Brokers Licensing Regulations for failure to advise a passenger and report non-compliance when an official email showed a consignment contained other passengers' baggage, constituting breach of the broker's duty to inform. The tribunal found provisions on client identification and valuation inapplicable where the passenger was personally present and where valuation was not within the broker's authority. Fraud by an employee outside authority did not attract company liability. Electronic email evidence was treated as decisive and unrefuted, licence revocation and security forfeiture were set aside, but a monetary penalty was confirmed for the duty breach.
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