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...
Classification of imported goods - freely importable Waste Paper - There are no cogent reasons with clear evidences are adduced on record by Revenue for discarding pre-shipment inspection certificate in toto. In absence of any inculpatory statements and there being no deliberate mis-declaration on the part of Appellants, confiscation of goods, and penalty are not sustainable, in the facts of these cases - the appellants are admittedly engaged in the manufacture of craft paper and other paper products and the imported goods i.e. paper waste in question is meant for use as raw material in their production. On this fact also it cannot be alleged that appellant has not imported the paper waste and something else. - AT
Classification of imported goods - freely importable Waste Paper - There are no cogent reasons with clear evidences are adduced on record by Revenue for discarding pre-shipment inspection certificate in toto. In absence of any inculpatory statements and there being no deliberate mis-declaration on the part of Appellants, confiscation of goods, and penalty are not sustainable, in the facts of these cases - the appellants are admittedly engaged in the manufacture of craft paper and other paper products and the imported goods i.e. paper waste in question is meant for use as raw material in their production. On this fact also it cannot be alleged that appellant has not imported the paper waste and something else. - AT
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