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/r 25 of CER - Penalty on Registered Dealers, Unregistered Dealers and Transporters - Availment of fraudulent credit - issuance of Cenvatable invoices without actual dispatch of goods - The Tribunal held that penalties could indeed be imposed on registered dealers under Rule 25 for issuing Cenvatable invoices without actual movement of goods. The Tribunal found that the dealers had contravened the rules with the intent to evade payment of duty. - The Tribunal held that penalties were warranted for unregistered dealers and transporters who facilitated fraudulent activities, despite their claims that the goods did not reach the intended destination. The Tribunal emphasized the liability of all involved parties in facilitating fraudulent activities.
Levy of penalty u/r 25 of CER - Penalty on Registered Dealers, Unregistered Dealers and Transporters - Availment of fraudulent credit - issuance of Cenvatable invoices without actual dispatch of goods - The Tribunal held that penalties could indeed be imposed on registered dealers under Rule 25 for issuing Cenvatable invoices without actual movement of goods. The Tribunal found that the dealers had contravened the rules with the intent to evade payment of duty. - The Tribunal held that penalties were warranted for unregistered dealers and transporters who facilitated fraudulent activities, despite their claims that the goods did not reach the intended destination. The Tribunal emphasized the liability of all involved parties in facilitating fraudulent activities.
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