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...
Seizure of assorted diamond studded jewellery - The Respondent cannot be directed to accept the report when it was found to be unreliable. The Respondent Authorities have gone by the basic criteria of valuing the goods in question by considering the transactional value based on invoices found in possession of the Petitioner himself. Despite the same, Authorities at each stage have taken a lenient view and have reduced redemption and personal fines. - HC
Seizure of assorted diamond studded jewellery - The Respondent cannot be directed to accept the report when it was found to be unreliable. The Respondent Authorities have gone by the basic criteria of valuing the goods in question by considering the transactional value based on invoices found in possession of the Petitioner himself. Despite the same, Authorities at each stage have taken a lenient view and have reduced redemption and personal fines. - HC
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