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 - Enhancement of value of the imported RPO - CESTAT held that, in the present case neither any contemporaneous value was adopted nor any method as prescribed u/s 14 read with Custom Valuation Rules, 2007 was followed. Therefore, merely on the basis of statements of director valuation cannot be enhanced. - Further regarding the Mis-declaration of Country of Origin in the bills of entry, the Tribunal held that, if there is a mis-declaration of country of origin the appellant being not the party to make any incorrect declaration cannot be held responsible and no consequential penalty can be imposed on the appellant.
Valuation - Enhancement of value of the imported RPO - CESTAT held that, in the present case neither any contemporaneous value was adopted nor any method as prescribed u/s 14 read with Custom Valuation Rules, 2007 was followed. Therefore, merely on the basis of statements of director valuation cannot be enhanced. - Further regarding the Mis-declaration of Country of Origin in the bills of entry, the Tribunal held that, if there is a mis-declaration of country of origin the appellant being not the party to make any incorrect declaration cannot be held responsible and no consequential penalty can be imposed on the appellant.
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