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...
Penalty on Customs Broker under Regulation 18 of CBLR, 2018 - violation of regulation 10(o) and Regulation 10(b) - Despite allegations of the exporter attempting fraudulent exports to avail excess GST refunds, the tribunal found no evidence of collusion between the appellant and the exporter. Therefore, holding the appellant accountable for the exporter's actions without any proof of collusion would be unjust. Penalty set aside.
Penalty on Customs Broker under Regulation 18 of CBLR, 2018 - violation of regulation 10(o) and Regulation 10(b) - Despite allegations of the exporter attempting fraudulent exports to avail excess GST refunds, the tribunal found no evidence of collusion between the appellant and the exporter. Therefore, holding the appellant accountable for the exporter's actions without any proof of collusion would be unjust. Penalty set aside.
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