Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Customs Broker licence revocation, forfeiture of security deposit and penalty were set aside because the record did not provide substantive evidence linking the broker to the impugned export shipments or showing knowledge of the alleged fraud. The Tribunal held that the Shipping Bills and other primary documents indicated the exporters themselves had filed the consignments, while the allegation depended mainly on a G-Card holder's statement. The challenge based on Regulation 17 timelines failed because the inquiry report was found to have been submitted within the prescribed period and the broker was given an opportunity to respond. The complaint of denial of cross-examination also failed because no witness was identified for examination.
Customs Broker licence revocation, forfeiture of security deposit and penalty were set aside because the record did not provide substantive evidence linking the broker to the impugned export shipments or showing knowledge of the alleged fraud. The Tribunal held that the Shipping Bills and other primary documents indicated the exporters themselves had filed the consignments, while the allegation depended mainly on a G-Card holder's statement. The challenge based on Regulation 17 timelines failed because the inquiry report was found to have been submitted within the prescribed period and the broker was given an opportunity to respond. The complaint of denial of cross-examination also failed because no witness was identified for examination.
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