Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
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...
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Clandestine manufacture - tobacco snuff - It is found that to manufacture snuff of huge quantity, other raw material/packing material also required but no such evidence of procurement of other raw material/packing material on record. Without evidence on record from where quantity of other raw material/packing material has been procured by the appellant used in manufacture of snuff which has been cleared without payment of duty, the charge of clandestine removal of snuff against the appellant is not sustainable. - AT
Clandestine manufacture - tobacco snuff - It is found that to manufacture snuff of huge quantity, other raw material/packing material also required but no such evidence of procurement of other raw material/packing material on record. Without evidence on record from where quantity of other raw material/packing material has been procured by the appellant used in manufacture of snuff which has been cleared without payment of duty, the charge of clandestine removal of snuff against the appellant is not sustainable. - AT
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