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...
Importers using transferable duty credit scrips through authorised customs clearance agents remain responsible for acts performed within the agent's authority when they retain the resulting duty benefit. Bona fide purchaser protection requires good faith and reasonable verification of a scrip's genuineness, validity and available credit; caveat emptor places that due-diligence burden on the importer. Incorrect Bill of Entry declarations and failure to investigate irregular clearance arrangements undermine that protection. Natural justice requires demonstrable prejudice: non-production of original scrips or denial of cross-examination does not invalidate proceedings where independent entitlement, transaction and investigation evidence establishes the facts. Fraud-related short-levy penalties may apply despite no personal execution of EDI manipulation, but separate overlapping penalties are mutually exclusive.
Importers using transferable duty credit scrips through authorised customs clearance agents remain responsible for acts performed within the agent's authority when they retain the resulting duty benefit. Bona fide purchaser protection requires good faith and reasonable verification of a scrip's genuineness, validity and available credit; caveat emptor places that due-diligence burden on the importer. Incorrect Bill of Entry declarations and failure to investigate irregular clearance arrangements undermine that protection. Natural justice requires demonstrable prejudice: non-production of original scrips or denial of cross-examination does not invalidate proceedings where independent entitlement, transaction and investigation evidence establishes the facts. Fraud-related short-levy penalties may apply despite no personal execution of EDI manipulation, but separate overlapping penalties are mutually exclusive.
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