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...
Clandestine removal - Goods cleared without issuing invoices and CE duty was leviable on those goods - admission by the party itself - admissible evidences or not - In view of the specific admissions by the Director, nothing further was required to be proved by the Department and also the recovery of challans during visit of factory clearly proves that goods so manufactured were clandestinely cleared from the factory under the guise of job work on which no Excise duty was paid. It is a settled principle of law that what is admitted by a party need not be proved. - AT
Clandestine removal - Goods cleared without issuing invoices and CE duty was leviable on those goods - admission by the party itself - admissible evidences or not - In view of the specific admissions by the Director, nothing further was required to be proved by the Department and also the recovery of challans during visit of factory clearly proves that goods so manufactured were clandestinely cleared from the factory under the guise of job work on which no Excise duty was paid. It is a settled principle of law that what is admitted by a party need not be proved. - AT
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