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...
Customs supervision charges for a special warehouse depend on the recovery mode determined after assessing operational requirements and distance from the customs office. Cost-recovery charges apply where Customs officers are additionally sanctioned and exclusively posted beyond regular staffing, whereas Merchant Overtime charges apply where supervision is charged, paid and accepted on that basis. An undertaking to bear Customs supervision costs does not prescribe either method as the exclusive recovery mode. Differential cost-recovery charges cannot rest on an assumed Inspector posting where no proposal or actual exclusive cost-recovery posting exists.
Customs supervision charges for a special warehouse depend on the recovery mode determined after assessing operational requirements and distance from the customs office. Cost-recovery charges apply where Customs officers are additionally sanctioned and exclusively posted beyond regular staffing, whereas Merchant Overtime charges apply where supervision is charged, paid and accepted on that basis. An undertaking to bear Customs supervision costs does not prescribe either method as the exclusive recovery mode. Differential cost-recovery charges cannot rest on an assumed Inspector posting where no proposal or actual exclusive cost-recovery posting exists.
Note: It is a system-generated summary and is for quick reference only.