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 - it is found that if the system is not designed to send an alert to the Customs Broker if a Shipping Bill is filed in its name in the service centre at the Custom House and only sends an alert if it is filed online, it cannot be fathomed how the appellant can be faulted if this loophole in the system was exploited by another person after making a fake Customs card. - AT
Revocation of Customs Broker License - it is found that if the system is not designed to send an alert to the Customs Broker if a Shipping Bill is filed in its name in the service centre at the Custom House and only sends an alert if it is filed online, it cannot be fathomed how the appellant can be faulted if this loophole in the system was exploited by another person after making a fake Customs card. - AT
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