Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
The High Court held that a customs broker who merely filed documents supplied by the importer had acted as a ministerial conduit, with no evidence of knowledge, intentional suppression, or participation in fraud. Those findings were factual and showed no perversity, so no substantial question of law arose under Section 130 of the Customs Act. The Court also held that, because the penalty against the respondent had been set aside in full, there was no quantified liability surviving against him and the Revenue could not rely on the investigation's overall value or the importer's separate liability to cross the monetary threshold for appeal. The appeal was not admitted and was dismissed.
The High Court held that a customs broker who merely filed documents supplied by the importer had acted as a ministerial conduit, with no evidence of knowledge, intentional suppression, or participation in fraud. Those findings were factual and showed no perversity, so no substantial question of law arose under Section 130 of the Customs Act. The Court also held that, because the penalty against the respondent had been set aside in full, there was no quantified liability surviving against him and the Revenue could not rely on the investigation's overall value or the importer's separate liability to cross the monetary threshold for appeal. The appeal was not admitted and was dismissed.
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