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...
Fire-damaged motor cars brought with a vessel for ship-breaking may be classified as scrap where extensive damage has destroyed their identity and utility as motor vehicles, and salvage arrangements restrict disposal to demolition. Such goods are not restricted commercial or passenger vehicles, usable second-hand goods, or prohibited imports; confiscation for import without a licence is therefore not attracted. Unloading requires physical removal of cargo from a vessel; berthing at a notified ship-breaking port is not unloading. Where no unauthorised removal or other statutory contravention is established, neither the scrap cargo nor the vessel carrying it is liable to confiscation, and consequential penalties are unsustainable.
Fire-damaged motor cars brought with a vessel for ship-breaking may be classified as scrap where extensive damage has destroyed their identity and utility as motor vehicles, and salvage arrangements restrict disposal to demolition. Such goods are not restricted commercial or passenger vehicles, usable second-hand goods, or prohibited imports; confiscation for import without a licence is therefore not attracted. Unloading requires physical removal of cargo from a vessel; berthing at a notified ship-breaking port is not unloading. Where no unauthorised removal or other statutory contravention is established, neither the scrap cargo nor the vessel carrying it is liable to confiscation, and consequential penalties are unsustainable.
Note: It is a system-generated summary and is for quick reference only.
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