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...
Clandestine Removal - reliability of statements - sufficiency of evidence or not - In a serious case such as evasion of duty by fraud, the degree of appreciation of evidence has to be higher than in a case of allegation of mere delay in payment of duty though in both cases the evidence has to be appreciated on the preponderance of probability. - there is enough evidence to establish the case put forth by department. The role of the Managing Director in such activity is also clear. - AT
Clandestine Removal - reliability of statements - sufficiency of evidence or not - In a serious case such as evasion of duty by fraud, the degree of appreciation of evidence has to be higher than in a case of allegation of mere delay in payment of duty though in both cases the evidence has to be appreciated on the preponderance of probability. - there is enough evidence to establish the case put forth by department. The role of the Managing Director in such activity is also clear. - AT
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