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...
Seeking to recover the refund of SAD already sanctioned - imported timber log and paid SAD - The Tribunal upheld the appellant's contention that they were entitled to the refund despite selling cut and sawn timber logs. Citing legal precedents and the purpose of the exemption notification, the Tribunal ruled that the conversion of logs did not disqualify the appellant from the refund. - The Tribunal agreed with the appellant that as they were not registered dealers, the requirement for endorsement on invoices did not apply to them.
Seeking to recover the refund of SAD already sanctioned - imported timber log and paid SAD - The Tribunal upheld the appellant's contention that they were entitled to the refund despite selling cut and sawn timber logs. Citing legal precedents and the purpose of the exemption notification, the Tribunal ruled that the conversion of logs did not disqualify the appellant from the refund. - The Tribunal agreed with the appellant that as they were not registered dealers, the requirement for endorsement on invoices did not apply to them.
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