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...
Seeking amendment in the bills of entry - excess duty payment by mistake - Had the Department considered the appellant’s request for amendment of its Bill of Entry then, perhaps, the alleged delay, etc. would not have arisen at all. The appellant had correctly and in line with the dictum of the Hon’ble Apex Court in the case of ITC Ltd. (Supra) requested for amendment and it was at the instance of the Department that a refund application was also filed. - Amendment allowed - AT
Seeking amendment in the bills of entry - excess duty payment by mistake - Had the Department considered the appellant’s request for amendment of its Bill of Entry then, perhaps, the alleged delay, etc. would not have arisen at all. The appellant had correctly and in line with the dictum of the Hon’ble Apex Court in the case of ITC Ltd. (Supra) requested for amendment and it was at the instance of the Department that a refund application was also filed. - Amendment allowed - AT
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