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...
Valuation of imported goods - Aluminium Scrap - rejection of transaction value - procedure contemplated under Rule 12 of the valuation rules not followed - Commissioner of Customs (Appeals), while allowing the appeal of the importer, set aside the re-assessment of goods at enhanced value and restored the self-assessment at the declared value - when the importer has voluntarily accepted the enhanced value without any protest then in that case it is not incumbent upon the department to pass a speaking order. - AT
Valuation of imported goods - Aluminium Scrap - rejection of transaction value - procedure contemplated under Rule 12 of the valuation rules not followed - Commissioner of Customs (Appeals), while allowing the appeal of the importer, set aside the re-assessment of goods at enhanced value and restored the self-assessment at the declared value - when the importer has voluntarily accepted the enhanced value without any protest then in that case it is not incumbent upon the department to pass a speaking order. - AT
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