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...
Imposition of redemption fine - import of Limestone Blocks - imported goods not covered by the license - confiscation of goods - The Tribunal observed the circumstances, including the timing of the shipments and the Appellant's voluntary disclosure of the license lapse. - Considering the Appellant's bonafide actions and the impact of heavy demurrage charges, the Tribunal decided to grant leniency in the quantum of redemption fine and penalty.
Imposition of redemption fine - import of Limestone Blocks - imported goods not covered by the license - confiscation of goods - The Tribunal observed the circumstances, including the timing of the shipments and the Appellant's voluntary disclosure of the license lapse. - Considering the Appellant's bonafide actions and the impact of heavy demurrage charges, the Tribunal decided to grant leniency in the quantum of redemption fine and penalty.
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