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...
Levy of penalty - mis-conduct and moral turpitude - Customs Broker License - It is noted that it was imperative for the appellant to have with greater sincerity and due care taken measures to abide by the summons issued. This is all the more, relevant for them as they are a licensed Customs Broker and thus in a way being an extended arm of the department and an important interphase with the trading (importing and exporting) community, they had to be more vigilant and demonstrative in their actions and conduct. - Amount of penalty reduced - AT
Levy of penalty - mis-conduct and moral turpitude - Customs Broker License - It is noted that it was imperative for the appellant to have with greater sincerity and due care taken measures to abide by the summons issued. This is all the more, relevant for them as they are a licensed Customs Broker and thus in a way being an extended arm of the department and an important interphase with the trading (importing and exporting) community, they had to be more vigilant and demonstrative in their actions and conduct. - Amount of penalty reduced - AT
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