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...
Interpretation of statute - meaning of the expression ‘reason to believe’ and ‘liable to confiscation’ u/s 110 of the Customs Act, 1962 - import of prohibited goods - betel nuts - cut dried Areca Nuts (dark pink in colour) - There is no track record of past history of the instant petitioners - ‘reason to believe’ cannot be converted into a formalised procedural roadblock
Interpretation of statute - meaning of the expression ‘reason to believe’ and ‘liable to confiscation’ u/s 110 of the Customs Act, 1962 - import of prohibited goods - betel nuts - cut dried Areca Nuts (dark pink in colour) - There is no track record of past history of the instant petitioners - ‘reason to believe’ cannot be converted into a formalised procedural roadblock
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