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...
Steamer agents who lodge and verify an Import General Manifest as agents of a vessel's master may be treated as persons-in-charge of the conveyance for Customs purposes. The statutory responsibility covers proper accounting for manifested cargo, and liability for a cargo deficiency may arise where the agent cannot satisfactorily explain the shortfall. Import General Manifest filing is a verified declaration rather than mere notice of arrival; contractual terms in bills of lading do not displace that obligation. High Court answered the legal questions in Revenue's favour, restored the penalty for the unexplained deficiency, and set aside the Tribunal's contrary order.
Steamer agents who lodge and verify an Import General Manifest as agents of a vessel's master may be treated as persons-in-charge of the conveyance for Customs purposes. The statutory responsibility covers proper accounting for manifested cargo, and liability for a cargo deficiency may arise where the agent cannot satisfactorily explain the shortfall. Import General Manifest filing is a verified declaration rather than mere notice of arrival; contractual terms in bills of lading do not displace that obligation. High Court answered the legal questions in Revenue's favour, restored the penalty for the unexplained deficiency, and set aside the Tribunal's contrary order.
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