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/r 26 of CER on the buyer / purchaser of goods - The Revenue has not brought on record as to the role of the appellant in the non-payment of Excise Duty by the said manufacturer; the appellant has pleaded that it was only procuring the said AVS and the only relationship that existed was that of manufacturer and purchaser and nothing more than that, which is not disputed by the Revenue. - No penalty - AT
Levy of Penalty u/r 26 of CER on the buyer / purchaser of goods - The Revenue has not brought on record as to the role of the appellant in the non-payment of Excise Duty by the said manufacturer; the appellant has pleaded that it was only procuring the said AVS and the only relationship that existed was that of manufacturer and purchaser and nothing more than that, which is not disputed by the Revenue. - No penalty - AT
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