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...
Undervaluation of the imported goods - Rejection of transaction value - Having rejected the declared assessable value under Rule 12, the department sought to re-determine it under Rule 5 based on the contemporaneous value of similar goods imported into the country. - To determine the value of the contemporaneous imports, the relevant data was extracted from the NIDB. - Importer has also accepted the same - Demand confirmed - AT
Undervaluation of the imported goods - Rejection of transaction value - Having rejected the declared assessable value under Rule 12, the department sought to re-determine it under Rule 5 based on the contemporaneous value of similar goods imported into the country. - To determine the value of the contemporaneous imports, the relevant data was extracted from the NIDB. - Importer has also accepted the same - Demand confirmed - AT
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