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...
Valuation of 125 consignments of imported toys - applicable tariff concession @ 43% or tariff concession @8% - once the order dated September 29, 2021 passed by the Commissioner (Appeals) was accepted by the competent authority on December 27, 2021, the Department cannot be permitted to take a different stand in the present appeal filed by the appellant. - AT
Valuation of 125 consignments of imported toys - applicable tariff concession @ 43% or tariff concession @8% - once the order dated September 29, 2021 passed by the Commissioner (Appeals) was accepted by the competent authority on December 27, 2021, the Department cannot be permitted to take a different stand in the present appeal filed by the appellant. - AT
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