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 - Smuggling - imitation jewellery raw material glass beads (Chatons) in the guise of clearing glass show piece/scrubbers/foot wear - In any case, it is not the case of the Department that those two persons had gained unauthorized access and that the appellant had helped in any way, in accommodating the unauthorized access or exit from the scene. - There is otherwise no allegation by the Revenue as to security and access control and therefore, the penalty cannot be sustained. - AT
Levy of penalty - Smuggling - imitation jewellery raw material glass beads (Chatons) in the guise of clearing glass show piece/scrubbers/foot wear - In any case, it is not the case of the Department that those two persons had gained unauthorized access and that the appellant had helped in any way, in accommodating the unauthorized access or exit from the scene. - There is otherwise no allegation by the Revenue as to security and access control and therefore, the penalty cannot be sustained. - AT
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