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...
Confiscation - absence of the BIS stickers on the Cold Rolled Non-Grain Oriented Silicon Steel Sheet in Coil - the bona fide of the appellant is evident on the face of the record as they offered to re-export the goods, on the clearance being object to for domestic consumption - There is no deliberate breach of the quality control order and for the venial breach the provisions of confiscation and penalty are not attracted - AT
Confiscation - absence of the BIS stickers on the Cold Rolled Non-Grain Oriented Silicon Steel Sheet in Coil - the bona fide of the appellant is evident on the face of the record as they offered to re-export the goods, on the clearance being object to for domestic consumption - There is no deliberate breach of the quality control order and for the venial breach the provisions of confiscation and penalty are not attracted - AT
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