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...
Refrain from imposition of penalty - classification of imported goods - colour data projectors - It is only when there is any ambiguity in the Exemption Notification, that the Notification is required to be interpreted in favour of the Revenue - There is no ambiguity in the Exemption Notification dated 1st March, 2005 and indeed none has been pointed out by the Commissioner in the impugned order. - When penalty is not proposed in the Show cause notice (SCN), no penalty can be imposed - AT
Refrain from imposition of penalty - classification of imported goods - colour data projectors - It is only when there is any ambiguity in the Exemption Notification, that the Notification is required to be interpreted in favour of the Revenue - There is no ambiguity in the Exemption Notification dated 1st March, 2005 and indeed none has been pointed out by the Commissioner in the impugned order. - When penalty is not proposed in the Show cause notice (SCN), no penalty can be imposed - AT
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