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...
MEIS scheme - amendment in the shipping bills - whether to permit the necessary amendments in the shipping bills would be within the purview of the Commissioner of Customs himself and not the DGFT. It is only if the Commissioner of Customs permits such amendments in the shipping bills, then the DGFT would come into picture. It is also not clear from the impugned communications as to why such amendments have been declined. No reason has been assigned. - HC
MEIS scheme - amendment in the shipping bills - whether to permit the necessary amendments in the shipping bills would be within the purview of the Commissioner of Customs himself and not the DGFT. It is only if the Commissioner of Customs permits such amendments in the shipping bills, then the DGFT would come into picture. It is also not clear from the impugned communications as to why such amendments have been declined. No reason has been assigned. - HC
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