Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
Penalty under Section 112(a) was held unsustainable against a Customs House Agent who only assisted in filing the Bill of Entry on a self-declared basis. The Tribunal found no corroborative evidence that the CHA had prior knowledge of the concealment of the smuggled goods, and noted that the penalty against the alleged mastermind had already been set aside. It also considered that no proceedings had been initiated against the CHA under the Customs Broker Licensing Regulations. In the absence of proof of knowledge of concealment and licensing-regulation action, the penalty was set aside and the appeal was allowed.
Penalty under Section 112(a) was held unsustainable against a Customs House Agent who only assisted in filing the Bill of Entry on a self-declared basis. The Tribunal found no corroborative evidence that the CHA had prior knowledge of the concealment of the smuggled goods, and noted that the penalty against the alleged mastermind had already been set aside. It also considered that no proceedings had been initiated against the CHA under the Customs Broker Licensing Regulations. In the absence of proof of knowledge of concealment and licensing-regulation action, the penalty was set aside and the appeal was allowed.
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TaxTMI 
TaxTMI 
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