Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
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...
Claim of duty drawback, refund of IGST and state levies - Valuation of export goods - The Tribunal's decision underscores the importance of adhering to the legal provisions and procedures for valuation of export goods, particularly emphasizing the primary basis of transaction value for valuation, and the necessity for Customs authorities to quickly undertake necessary actions like tests or inquiries to minimize detention of goods. The decision also reflects the principle that penal liability for overvaluation cannot be fastened on exporters in the absence of substantial evidence or proper application of valuation rules. - AT
Claim of duty drawback, refund of IGST and state levies - Valuation of export goods - The Tribunal's decision underscores the importance of adhering to the legal provisions and procedures for valuation of export goods, particularly emphasizing the primary basis of transaction value for valuation, and the necessity for Customs authorities to quickly undertake necessary actions like tests or inquiries to minimize detention of goods. The decision also reflects the principle that penal liability for overvaluation cannot be fastened on exporters in the absence of substantial evidence or proper application of valuation rules. - AT
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