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...
Revocation of Customs Broker License - there is not even an assertion by the Revenue that on the day the Shipping Bills were filed the exporters did not exist at the premises. - The evidence available on record in the form of verification reports relied upon in the SCNs are vague and in some cases, even the name of the exporter who they were enquiring about is not indicated in them - Order of revocation, forfeiture of security deposit and penalty set aside - AT
Revocation of Customs Broker License - there is not even an assertion by the Revenue that on the day the Shipping Bills were filed the exporters did not exist at the premises. - The evidence available on record in the form of verification reports relied upon in the SCNs are vague and in some cases, even the name of the exporter who they were enquiring about is not indicated in them - Order of revocation, forfeiture of security deposit and penalty set aside - AT
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