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 u/s 117 - connivance in overvaluation of goods imported - Employees of the Customs Broker - A perusal of the impugned order does not point out as to what was expected of the present appellant, being one of innumerable employees of the Customs Broker, as his duty to comply with, which the appellant had ‘failed’ to perform. Insofar as this appellant is concerned, the Commissioner himself has observed that there was no direct evidence of connivance. - No penalty - AT
Levy of penalty u/s 117 - connivance in overvaluation of goods imported - Employees of the Customs Broker - A perusal of the impugned order does not point out as to what was expected of the present appellant, being one of innumerable employees of the Customs Broker, as his duty to comply with, which the appellant had ‘failed’ to perform. Insofar as this appellant is concerned, the Commissioner himself has observed that there was no direct evidence of connivance. - No penalty - AT
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