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...
Re-export of seized imported goods was permitted because the goods had remained under seizure for over a year, samples had already been drawn and tested, and their continued retention served no useful purpose. The Court did not examine the merits of the allegations of misclassification, undervaluation, or breach of minimum import price conditions. As the respondents did not seriously oppose re-export, permission was granted subject to safeguards: execution of a bond for the differential duty liability and furnishing of a bank guarantee equal to 5% of the re-determined value.
Re-export of seized imported goods was permitted because the goods had remained under seizure for over a year, samples had already been drawn and tested, and their continued retention served no useful purpose. The Court did not examine the merits of the allegations of misclassification, undervaluation, or breach of minimum import price conditions. As the respondents did not seriously oppose re-export, permission was granted subject to safeguards: execution of a bond for the differential duty liability and furnishing of a bank guarantee equal to 5% of the re-determined value.
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