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...
Mis-declaration of import goods - woven fabric - at the instance of the appellant goods were put to test for ascertainment of its description and classification before clearance - there is nothing on record that the samples drawn by DRI Officials were the representative samples of the consignment cleared in the disputed Bill of entry except the statement of Shri Rajbir Singh whose veracity is not tested through cross-examination - no additional duty/penalty
Mis-declaration of import goods - woven fabric - at the instance of the appellant goods were put to test for ascertainment of its description and classification before clearance - there is nothing on record that the samples drawn by DRI Officials were the representative samples of the consignment cleared in the disputed Bill of entry except the statement of Shri Rajbir Singh whose veracity is not tested through cross-examination - no additional duty/penalty
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