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 - the undeclared ‘drill bits’ constituted just a mere 5% of the total consignment, it would appear that there has been no deliberate attempt to mis-declare on the part of the importer - the confiscation of the goods under section 112(m) of Customs Act, 1962 and the imposition of redemption fine, along with penalties, does not appear to be sustainable in law.
Confiscation - the undeclared ‘drill bits’ constituted just a mere 5% of the total consignment, it would appear that there has been no deliberate attempt to mis-declare on the part of the importer - the confiscation of the goods under section 112(m) of Customs Act, 1962 and the imposition of redemption fine, along with penalties, does not appear to be sustainable in law.
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