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...
Smuggling - Rejection of request of importer for provisional release of seized currency - it is clear that belief of the department about the impugned currency notes to be the sale proceeds of imported goods allegedly under-valued goods, but otherwise not alleged to be smuggled goods cannot, be a reason to deny the provisional release of the said currency. The said belief is still to be proved by the department - AT
Smuggling - Rejection of request of importer for provisional release of seized currency - it is clear that belief of the department about the impugned currency notes to be the sale proceeds of imported goods allegedly under-valued goods, but otherwise not alleged to be smuggled goods cannot, be a reason to deny the provisional release of the said currency. The said belief is still to be proved by the department - AT
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