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 112(a) and Section 114AA of CA on Chartered Engineer - Issuance of Certificate under EPCG scheme without verification - The case involved the issuance of a Chartered Engineer Certificate for the installation and use of imported machinery under the EPCG scheme without verifying whether the machines were actually installed. The Department imposed penalties for non-compliance with verification requirements. The appellant argued good faith reliance on submitted documents and emphasized their limited role in verifying installation. However, the Tribunal held them liable for penalties, considering the seriousness of the offense.
Levy of penalty u/s 112(a) and Section 114AA of CA on Chartered Engineer - Issuance of Certificate under EPCG scheme without verification - The case involved the issuance of a Chartered Engineer Certificate for the installation and use of imported machinery under the EPCG scheme without verifying whether the machines were actually installed. The Department imposed penalties for non-compliance with verification requirements. The appellant argued good faith reliance on submitted documents and emphasized their limited role in verifying installation. However, the Tribunal held them liable for penalties, considering the seriousness of the offense.
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