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...
Imported scrap valuation was discussed in the context of reassessment based on NIDB data and contemporaneous imports. The Tribunal applied its earlier ruling, following the Delhi High Court view, that enhancement of declared value cannot rest solely on such data without legally sufficient justification under the valuation scheme, and that payment of enhanced duty to obtain clearance does not prevent the importer from challenging the reassessment in appeal. On that basis, the impugned order was held unsustainable and the appeals were allowed with consequential relief.
Imported scrap valuation was discussed in the context of reassessment based on NIDB data and contemporaneous imports. The Tribunal applied its earlier ruling, following the Delhi High Court view, that enhancement of declared value cannot rest solely on such data without legally sufficient justification under the valuation scheme, and that payment of enhanced duty to obtain clearance does not prevent the importer from challenging the reassessment in appeal. On that basis, the impugned order was held unsustainable and the appeals were allowed with consequential relief.
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