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...
Penalty u/s 114A and 114(iii) - only allegation against the appellants is that they have availed draw back claim wrongly - in the show-cause notice there is no proposal for confiscation of the goods - No penalty - AT
Penalty u/s 114A and 114(iii) - only allegation against the appellants is that they have availed draw back claim wrongly - in the show-cause notice there is no proposal for confiscation of the goods - No penalty - AT
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