Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Immediate suspension of a customs broker licence under the licensing regulations requires appropriateness, an evidential basis linking the broker to the alleged misconduct, and compliance with procedural safeguards including a post-decisional hearing and recorded reasons when continuing suspension; the Tribunal found the impugned continuing suspension legally unsustainable because the order failed to demonstrate necessity, did not record reasons, lacked evidence that the appellants handled the impugned imports, and predated the show-cause notice; the Tribunal set aside the suspension, directed completion of the pending licensing inquiry expeditiously, and permitted the appellants to resume brokering business pending that inquiry.
Immediate suspension of a customs broker licence under the licensing regulations requires appropriateness, an evidential basis linking the broker to the alleged misconduct, and compliance with procedural safeguards including a post-decisional hearing and recorded reasons when continuing suspension; the Tribunal found the impugned continuing suspension legally unsustainable because the order failed to demonstrate necessity, did not record reasons, lacked evidence that the appellants handled the impugned imports, and predated the show-cause notice; the Tribunal set aside the suspension, directed completion of the pending licensing inquiry expeditiously, and permitted the appellants to resume brokering business pending that inquiry.
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