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...
Availment of fraudulent duty drawback claim - Fabrication and forging of documents - IThe case is full of flaws. It is not explained why for many years Revenue did not get the handwriting of the accused verified by the handwriting expert. This is especially so when Shri GS Kohli admittedly forged the signatures of all other agencies such as banks, steamer agents, RBI, DGFT etc - AT
Availment of fraudulent duty drawback claim - Fabrication and forging of documents - IThe case is full of flaws. It is not explained why for many years Revenue did not get the handwriting of the accused verified by the handwriting expert. This is especially so when Shri GS Kohli admittedly forged the signatures of all other agencies such as banks, steamer agents, RBI, DGFT etc - AT
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