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...
Voluntary statements made before Customs officers may serve as substantive evidence because Customs officers are not police officers for the statutory rule excluding police confessions. An unretracted statement, where no coercion is established and independent material corroborates its contents, may be relied upon to determine a Customs Broker's role in improper imports. Knowing advice to classify areca nuts under an incorrect tariff heading, claim an inapplicable exemption, and facilitate clearance of prohibited goods can establish abetment and justify penalties against both the Customs Broker and its director. The penalties were upheld because knowledge and intention were established through voluntary, corroborated evidence.
Voluntary statements made before Customs officers may serve as substantive evidence because Customs officers are not police officers for the statutory rule excluding police confessions. An unretracted statement, where no coercion is established and independent material corroborates its contents, may be relied upon to determine a Customs Broker's role in improper imports. Knowing advice to classify areca nuts under an incorrect tariff heading, claim an inapplicable exemption, and facilitate clearance of prohibited goods can establish abetment and justify penalties against both the Customs Broker and its director. The penalties were upheld because knowledge and intention were established through voluntary, corroborated evidence.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
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