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...
100% EOU - served from India scheme (SFIS) - Recovery of duties of customs foregone - There is no finding in the order of the original authority holding the goods liable to confiscation; the imposition of penalty under section 112 of Customs Act, 1962 is without authority of law. Neither is there any finding on the confiscability of goods under rule 25 of Central Excise Act, 1944 and the imposition of penalty thereunder is, therefore, without authority of law. - AT
100% EOU - served from India scheme (SFIS) - Recovery of duties of customs foregone - There is no finding in the order of the original authority holding the goods liable to confiscation; the imposition of penalty under section 112 of Customs Act, 1962 is without authority of law. Neither is there any finding on the confiscability of goods under rule 25 of Central Excise Act, 1944 and the imposition of penalty thereunder is, therefore, without authority of law. - AT
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