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...
Conduct of the Customs officers - The Commissioner of Customs needs to look into such approach of the officers and not take it lightly so as to prevent a likelihood that such officers for reasons best known to them acting contrary to the binding orders passed by this Court and this is one of such cases. In these circumstances, it is requested that the Commissioner of Customs to look into the issue on understanding of the legal matters by such officers as in the present case wherein the Assistant Commissioner has totally discarded to consider the binding effect of the orders of this Court. - HC
Conduct of the Customs officers - The Commissioner of Customs needs to look into such approach of the officers and not take it lightly so as to prevent a likelihood that such officers for reasons best known to them acting contrary to the binding orders passed by this Court and this is one of such cases. In these circumstances, it is requested that the Commissioner of Customs to look into the issue on understanding of the legal matters by such officers as in the present case wherein the Assistant Commissioner has totally discarded to consider the binding effect of the orders of this Court. - HC
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