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 redemption fine and penalty - re-export of goods - misdeclaration of goods - the penalty imposed under Section 112 (a) of the Customs Act, 1962 is proper. However, the penalty of Rs.7 lakhs appears to be on a higher side. The penalty calls for reduction and it is reduced to Rs. 2 lakhs - AT
Levy of redemption fine and penalty - re-export of goods - misdeclaration of goods - the penalty imposed under Section 112 (a) of the Customs Act, 1962 is proper. However, the penalty of Rs.7 lakhs appears to be on a higher side. The penalty calls for reduction and it is reduced to Rs. 2 lakhs - AT
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