Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
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...
The appellant had practice to pay the duty on provisional value at the time of removal of the goods and only on finalization of books of accounts the actual cost of manufacturing is arrived at and whenever there is a short of value, they were paying the differential duty - there is no suppression of facts and mala fide on the part of the appellants. Accordingly the demand for extended period is not sustainable.
The appellant had practice to pay the duty on provisional value at the time of removal of the goods and only on finalization of books of accounts the actual cost of manufacturing is arrived at and whenever there is a short of value, they were paying the differential duty - there is no suppression of facts and mala fide on the part of the appellants. Accordingly the demand for extended period is not sustainable.
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