Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
Penalty on a customs broker was not justified where employees independently took clients and filed Bills of Entry without the broker's knowledge, approval, or authorisation. The Tribunal found no evidence that the broker had any active role in the prohibited acts, and noted that the employees had admitted acting without the Managing Director's consent. It also considered the broker's action against the erring employees. In the absence of material showing knowledge, authorisation, or involvement, the penalty imposed under the relevant customs broker regulation was set aside.
Penalty on a customs broker was not justified where employees independently took clients and filed Bills of Entry without the broker's knowledge, approval, or authorisation. The Tribunal found no evidence that the broker had any active role in the prohibited acts, and noted that the employees had admitted acting without the Managing Director's consent. It also considered the broker's action against the erring employees. In the absence of material showing knowledge, authorisation, or involvement, the penalty imposed under the relevant customs broker regulation was set aside.
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