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 - imposition of redemption fine and penalties - mis-declaration of imported goods - the overseas supper had wrongly shipped different types of goods - However, it an admitted position that the importer-appellant did not take proper steps to check the cargo before presentation of the Bills of Entry for assessment purpose and accordingly, it cannot plead that the action on its part is entirely bonafide. - The quantum of redemption fine and penalty reduced - AT
Confiscation - imposition of redemption fine and penalties - mis-declaration of imported goods - the overseas supper had wrongly shipped different types of goods - However, it an admitted position that the importer-appellant did not take proper steps to check the cargo before presentation of the Bills of Entry for assessment purpose and accordingly, it cannot plead that the action on its part is entirely bonafide. - The quantum of redemption fine and penalty reduced - AT
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