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...
Seizure and detention of goods - Confiscation of goods - Section 130 of the Act - It has not been established that there was any contravention of any provision or any Rules with an "intent to evade payment of tax" - none of the ingredients which are required for confiscation existed in the present case and thus, the confiscation itself was wholly arbitrary and illegal. - HC
Seizure and detention of goods - Confiscation of goods - Section 130 of the Act - It has not been established that there was any contravention of any provision or any Rules with an "intent to evade payment of tax" - none of the ingredients which are required for confiscation existed in the present case and thus, the confiscation itself was wholly arbitrary and illegal. - HC
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