Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Interception before customs clearance meant the accused had not yet reached the stage where any declaration, statement or document could be made for customs purposes, so the prosecution failed to prove false declaration under Section 132. Concealment of gold in a waist belt could raise suspicion and suggest preparation, but criminal liability for Section 135 required proof beyond reasonable doubt of fraudulent evasion or an attempt to evade duty. Because the respondent was stopped before using the red or green channel, the case remained at preparation and did not establish an attempt. The acquittal on both charges was upheld.
Interception before customs clearance meant the accused had not yet reached the stage where any declaration, statement or document could be made for customs purposes, so the prosecution failed to prove false declaration under Section 132. Concealment of gold in a waist belt could raise suspicion and suggest preparation, but criminal liability for Section 135 required proof beyond reasonable doubt of fraudulent evasion or an attempt to evade duty. Because the respondent was stopped before using the red or green channel, the case remained at preparation and did not establish an attempt. The acquittal on both charges was upheld.
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