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...
Reversal of Duty Drawback - Advance Licence and duty drawback are mutually exclusive or not - The Circular proceeds on the basis that the inputs that are duty exempt constitute only a fraction of the over-all inputs used, as otherwise, the very purpose of the DD Scheme would become redundant. Abuse of the position, as recognized even under Circular No.19/2005 is not an impossibility. - The indigo blue used in the goods claiming duty drawback, is only a fraction. - Revenue appeal dismissed - HC
Reversal of Duty Drawback - Advance Licence and duty drawback are mutually exclusive or not - The Circular proceeds on the basis that the inputs that are duty exempt constitute only a fraction of the over-all inputs used, as otherwise, the very purpose of the DD Scheme would become redundant. Abuse of the position, as recognized even under Circular No.19/2005 is not an impossibility. - The indigo blue used in the goods claiming duty drawback, is only a fraction. - Revenue appeal dismissed - HC
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