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...
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Non-Vessel Operating Common Carriers acting as Customs Cargo Service Providers must waive detention and demurrage charges on goods seized by Customs under HCCAR. The sixty-day allowance for container detention where goods are detained for verification under SCMTR does not override that prohibition. Failure to implement a customs waiver certificate breaches applicable SCMTR obligations and can support immediate suspension of NVOCC registration. Post-decisional opportunity to make representations may satisfy natural justice following such immediate suspension.
Non-Vessel Operating Common Carriers acting as Customs Cargo Service Providers must waive detention and demurrage charges on goods seized by Customs under HCCAR. The sixty-day allowance for container detention where goods are detained for verification under SCMTR does not override that prohibition. Failure to implement a customs waiver certificate breaches applicable SCMTR obligations and can support immediate suspension of NVOCC registration. Post-decisional opportunity to make representations may satisfy natural justice following such immediate suspension.
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