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...
Availability of an appellate remedy under the Customs Act requires parties challenging orders-in-original to pursue the statutory appeal rather than seek writ relief on the merits. Attached bank accounts may be released pending that appeal where Revenue is secured through appropriation of the statutory pre-deposit from the attached funds and an unconditional bank guarantee for the remaining demand. On fulfilment of both conditions, the accounts may be operated to enable business continuity; failure to file the appeal or provide the required security permits appropriation of the entire amount due.
Availability of an appellate remedy under the Customs Act requires parties challenging orders-in-original to pursue the statutory appeal rather than seek writ relief on the merits. Attached bank accounts may be released pending that appeal where Revenue is secured through appropriation of the statutory pre-deposit from the attached funds and an unconditional bank guarantee for the remaining demand. On fulfilment of both conditions, the accounts may be operated to enable business continuity; failure to file the appeal or provide the required security permits appropriation of the entire amount due.
Note: It is a system-generated summary and is for quick reference only.
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