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...
Levy of penalty u/s 114 of the Customs Act - appellant is a freight forwarder - export of non-basmati rice - prohibited goods or not - admittedly in the course of various statements recorded on different dates from this appellant he has admitted the modus operandi and have stated in detail the modus operandi as well as the amount of remuneration he was getting from the Exporter, which leads to the conclusion that he had connived with the Exporter in the export of prohibited goods for money. - Levy of penalty confirmed at reduced amount - AT
Levy of penalty u/s 114 of the Customs Act - appellant is a freight forwarder - export of non-basmati rice - prohibited goods or not - admittedly in the course of various statements recorded on different dates from this appellant he has admitted the modus operandi and have stated in detail the modus operandi as well as the amount of remuneration he was getting from the Exporter, which leads to the conclusion that he had connived with the Exporter in the export of prohibited goods for money. - Levy of penalty confirmed at reduced amount - AT
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