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...
Levy of penalty on Customs Broker - no case is made out that the appellant CB have knowingly allowed the alleged mis-declaration by their client. It is established principle of law that mere facilitation without knowledge of consequences, would not amount to abetting an offence. - AT
Levy of penalty on Customs Broker - no case is made out that the appellant CB have knowingly allowed the alleged mis-declaration by their client. It is established principle of law that mere facilitation without knowledge of consequences, would not amount to abetting an offence. - AT
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