Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
The impact of imposing penalty and purpose of reduced penalty not fulfilled - deterring the appellant from repeating the offence - Continued violation of policy conditions - The Tribunal in the earlier cases had reduced the redemption fine and personal penalty by 90%. - It is noticed from the pattern of continuing violation that the redemption fine and penalty imposed earlier are not discouraging the repeat of offence. It is seen that the appellants continue to violate the import policy in respect of Minimum Import Price with impunity. - AT
The impact of imposing penalty and purpose of reduced penalty not fulfilled - deterring the appellant from repeating the offence - Continued violation of policy conditions - The Tribunal in the earlier cases had reduced the redemption fine and personal penalty by 90%. - It is noticed from the pattern of continuing violation that the redemption fine and penalty imposed earlier are not discouraging the repeat of offence. It is seen that the appellants continue to violate the import policy in respect of Minimum Import Price with impunity. - AT
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