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 112 (a) & (b) (iii) and 114A of the Customs Act, 1962 - importing rough precious stones by making huge overvaluation - goods not imported by actual importers but the imports are being managed by someone else behind them - it is clear that the appellant has deliberately and intentionally has not provided any such information which was false or incorrect. As such, in my opinion that penalty under section 114AA of the Customs Act, 1962 has wrongly been imposed upon him. - AT
Levy of penalty u/s 112 (a) & (b) (iii) and 114A of the Customs Act, 1962 - importing rough precious stones by making huge overvaluation - goods not imported by actual importers but the imports are being managed by someone else behind them - it is clear that the appellant has deliberately and intentionally has not provided any such information which was false or incorrect. As such, in my opinion that penalty under section 114AA of the Customs Act, 1962 has wrongly been imposed upon him. - AT
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