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...
Transferee importers using duty-free DFIA licences linked to fabricated exports must independently verify licence authenticity, underlying export documents and transfer release advice. Verification solely through the DGFT website is insufficient. Purchase through intermediaries does not remove customs duty, interest or penalty exposure where the importer fails to undertake due diligence with licensing or Customs authorities regarding the issuing exporter and claimed exports. The stated Tribunal approach treats absence of such verification as sufficient to sustain liability for imports made under fraudulent transferable export incentive licences.
Transferee importers using duty-free DFIA licences linked to fabricated exports must independently verify licence authenticity, underlying export documents and transfer release advice. Verification solely through the DGFT website is insufficient. Purchase through intermediaries does not remove customs duty, interest or penalty exposure where the importer fails to undertake due diligence with licensing or Customs authorities regarding the issuing exporter and claimed exports. The stated Tribunal approach treats absence of such verification as sufficient to sustain liability for imports made under fraudulent transferable export incentive licences.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
