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...
Quantum of redemption fine and penalty - import of used digital multifunction machines - mis-declaration of value of goods - Considering the fact that the Department has also accepted the same in the case of M/s. Accord Digitech v. C.C., Bangalore, the tribunal held that in the interest of justice since 6 years have already been lapsed, the present appeal is partially allowed by reducing the redemption fine and penalty by 10% and 5% respectively of the enhanced value.
Quantum of redemption fine and penalty - import of used digital multifunction machines - mis-declaration of value of goods - Considering the fact that the Department has also accepted the same in the case of M/s. Accord Digitech v. C.C., Bangalore, the tribunal held that in the interest of justice since 6 years have already been lapsed, the present appeal is partially allowed by reducing the redemption fine and penalty by 10% and 5% respectively of the enhanced value.
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