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...
Revocation of a Customs Broker licence and forfeiture of security were disproportionate where the broker failed to verify authorisation and KYC documents, but the attempted prohibited export was actively undertaken by its employee and another person. Prompt action against the employee, absence of deliberate or intentional conduct by the broker, and no repeated violations supported retention of the licence with a penalty. Precedents involving repeated breaches and continuous licence misuse did not apply. The High Court upheld the Tribunal's proportionality finding, concluding that no substantial question of law arose.
Revocation of a Customs Broker licence and forfeiture of security were disproportionate where the broker failed to verify authorisation and KYC documents, but the attempted prohibited export was actively undertaken by its employee and another person. Prompt action against the employee, absence of deliberate or intentional conduct by the broker, and no repeated violations supported retention of the licence with a penalty. Precedents involving repeated breaches and continuous licence misuse did not apply. The High Court upheld the Tribunal's proportionality finding, concluding that no substantial question of law arose.
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TaxTMI 
TaxTMI 
of 4918 
