Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
Timelines under Regulation 17 of the Customs Brokers Licensing Regulations, 2018 were treated as mandatory, and failure to comply vitiated the proceedings. The High Court found that, on the undisputed dates, the inquiry report had been submitted beyond the 90-day period prescribed under Regulation 17(5). Rejecting the argument that the timeline was merely directory because no express consequence was stated, the Court held that non-adherence to the statutory period was sufficient to invalidate the action. The show cause notice and inquiry report were therefore quashed, and the writ petition was allowed.
Timelines under Regulation 17 of the Customs Brokers Licensing Regulations, 2018 were treated as mandatory, and failure to comply vitiated the proceedings. The High Court found that, on the undisputed dates, the inquiry report had been submitted beyond the 90-day period prescribed under Regulation 17(5). Rejecting the argument that the timeline was merely directory because no express consequence was stated, the Court held that non-adherence to the statutory period was sufficient to invalidate the action. The show cause notice and inquiry report were therefore quashed, and the writ petition was allowed.
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