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/s 114 of the Customs Act, 1962 on the owners of the seized goods - Allegation that, pulses (URAD ki Dal) in question were meant for illegal export from India to Nepal - Requirement to cross-examination of the witnesses. Genuineness of the Punchnama - panch witnesses are stated to be ‘daily wage laborers'. - The tribunal set aside the penalty in the absence of allowing cross-examination of witness.
Levy of penalty u/s 114 of the Customs Act, 1962 on the owners of the seized goods - Allegation that, pulses (URAD ki Dal) in question were meant for illegal export from India to Nepal - Requirement to cross-examination of the witnesses. Genuineness of the Punchnama - panch witnesses are stated to be ‘daily wage laborers'. - The tribunal set aside the penalty in the absence of allowing cross-examination of witness.
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