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...
Parity with an accepted co-ordinate Tribunal order supported setting aside revocation of a Customs Broker licence. The Tribunal had found that alleged contraventions of the Customs Broker Licensing Regulations, 2018 were not established in an analogous matter involving the same exporter. As the Revenue identified no material factual distinction and had accepted the earlier Tribunal decision without challenge, no substantial question of law arose. The High Court therefore upheld the setting aside of the licence revocation and dismissed the Revenue's appeal.
Parity with an accepted co-ordinate Tribunal order supported setting aside revocation of a Customs Broker licence. The Tribunal had found that alleged contraventions of the Customs Broker Licensing Regulations, 2018 were not established in an analogous matter involving the same exporter. As the Revenue identified no material factual distinction and had accepted the earlier Tribunal decision without challenge, no substantial question of law arose. The High Court therefore upheld the setting aside of the licence revocation and dismissed the Revenue's appeal.
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