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Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
An authorised courier was not liable for regulatory action or penalty for abetment of smuggling where no evidence established its involvement in, or knowledge of, gold concealed in consignment cartons. The concealment was detectable only by X-ray examination upon arrival, while the courier acted bona fide and exercised due diligence. Proceedings for penalty relating to the contraband had also been dropped. The Tribunal sustained the order dropping proceedings against the courier and dismissed the Revenue's appeal.
An authorised courier was not liable for regulatory action or penalty for abetment of smuggling where no evidence established its involvement in, or knowledge of, gold concealed in consignment cartons. The concealment was detectable only by X-ray examination upon arrival, while the courier acted bona fide and exercised due diligence. Proceedings for penalty relating to the contraband had also been dropped. The Tribunal sustained the order dropping proceedings against the courier and dismissed the Revenue's appeal.
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