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...
Jurisdiction - power of DRI to issue SCN u/s 28 of Customs Act - DRI are Proper Officers or not - availability of alternate remedy of appeal - In the present case, the entire proceedings are initiated by the respondent No. 2 - Joint Director, DRI, Mumbai, by issuing the show cause notice are invalid, without any authority of law and liable to be set aside and ensuing demands are also liable to be set aside. - HC
Jurisdiction - power of DRI to issue SCN u/s 28 of Customs Act - DRI are Proper Officers or not - availability of alternate remedy of appeal - In the present case, the entire proceedings are initiated by the respondent No. 2 - Joint Director, DRI, Mumbai, by issuing the show cause notice are invalid, without any authority of law and liable to be set aside and ensuing demands are also liable to be set aside. - HC
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