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...
Refund of Customs Duty - unjust enrichment - In this case, the goods brought under the impugned Bills of Entry are still in use by the respondents themselves and the Director (Operations & Technical) of the respondents, has also certified the same. In that circumstances, the respondent has passed the bar of unjust enrichment as the goods are in the possession of the respondent/importer. - AT
Refund of Customs Duty - unjust enrichment - In this case, the goods brought under the impugned Bills of Entry are still in use by the respondents themselves and the Director (Operations & Technical) of the respondents, has also certified the same. In that circumstances, the respondent has passed the bar of unjust enrichment as the goods are in the possession of the respondent/importer. - AT
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