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 u/r 18 of the CBLR, 2013 - allegation is on the ground that authorization / KYC documents was obtained from middleman instead of importer directly - the adjudicating authority is bound to put to notice the Customs Broker, setting out tentative conclusions or the points on which he differs from the Inquiry Officer. This would facilitate and ensure the right of Customs Broker to defend his case - AT
Levy of penalty on Customs Broker u/r 18 of the CBLR, 2013 - allegation is on the ground that authorization / KYC documents was obtained from middleman instead of importer directly - the adjudicating authority is bound to put to notice the Customs Broker, setting out tentative conclusions or the points on which he differs from the Inquiry Officer. This would facilitate and ensure the right of Customs Broker to defend his case - AT
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