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...
Adjudication of SCN after 25 years - about 30 years from the date of import - in the absence of Section 28(2A) of the the Customs Act, the adjudication proceedings have to be completed within a reasonable period and in the facts of the present case, pending adjudication of show cause notice for a period of 25 years cannot be said to be a reasonable period. - SCN quashed - HC
Adjudication of SCN after 25 years - about 30 years from the date of import - in the absence of Section 28(2A) of the the Customs Act, the adjudication proceedings have to be completed within a reasonable period and in the facts of the present case, pending adjudication of show cause notice for a period of 25 years cannot be said to be a reasonable period. - SCN quashed - HC
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