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 114 of CA - duty drawback - There is nothing on record to indicate the appellant M/s Exim Services had instructed/aided M/s Suryakiran International Limited for claiming ineligible drawback on the export of mis-declared and overvalued Denim Garments - No penalty.
Penalty u/s 114 of CA - duty drawback - There is nothing on record to indicate the appellant M/s Exim Services had instructed/aided M/s Suryakiran International Limited for claiming ineligible drawback on the export of mis-declared and overvalued Denim Garments - No penalty.
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