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...
Detention of goods - detention based on statement of driver regarding place of unloading of goods - route for transportation of goods disputed - The power of detention as well as seizure can be exercised only when the goods were not accompanying with the genuine documents provided under the Act. The genuineness of the documents has not been disputed at any stage - Once the documents accompanying the goods were found to be genuine the goods ought not be have been seized. - HC
Detention of goods - detention based on statement of driver regarding place of unloading of goods - route for transportation of goods disputed - The power of detention as well as seizure can be exercised only when the goods were not accompanying with the genuine documents provided under the Act. The genuineness of the documents has not been disputed at any stage - Once the documents accompanying the goods were found to be genuine the goods ought not be have been seized. - HC
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