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...
Food testing kits were held classifiable under CTI 3822 00 90, not CTI 3822 00 19, because they were meant for food testing and not diagnostic use; the importer's claim to exemption under Notification No. 50/2017-Cus for diagnostic test kits therefore failed. The Tribunal also held that describing the goods as "Diagnostic use only" in self-assessment amounted to conscious misdeclaration, justifying invocation of the extended period of limitation. On that basis, the penalties imposed on the importer and its directors were upheld, and the impugned order was sustained in full.
Food testing kits were held classifiable under CTI 3822 00 90, not CTI 3822 00 19, because they were meant for food testing and not diagnostic use; the importer's claim to exemption under Notification No. 50/2017-Cus for diagnostic test kits therefore failed. The Tribunal also held that describing the goods as "Diagnostic use only" in self-assessment amounted to conscious misdeclaration, justifying invocation of the extended period of limitation. On that basis, the penalties imposed on the importer and its directors were upheld, and the impugned order was sustained in full.
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