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...
Job-worker or manufacturer - Duty liability - The case revolved around the appellants' role as job workers in the manufacture of machine-made dipped matches, supplied with raw materials by another manufacturer. Despite not following the prescribed job work procedure, the Tribunal deemed it a procedural lapse and emphasized that duty liability rested with the raw material supplier. Citing relevant legal provisions and case law, the Tribunal set aside the demand for duty, interest, and penalties against the appellants. Furthermore, the Tribunal noted the principal manufacturer's participation in the Sabka Vishwas Scheme (SVLDRS), which had already discharged duty on the goods. Consequently, the Tribunal allowed the appeal with consequential relief.
Job-worker or manufacturer - Duty liability - The case revolved around the appellants' role as job workers in the manufacture of machine-made dipped matches, supplied with raw materials by another manufacturer. Despite not following the prescribed job work procedure, the Tribunal deemed it a procedural lapse and emphasized that duty liability rested with the raw material supplier. Citing relevant legal provisions and case law, the Tribunal set aside the demand for duty, interest, and penalties against the appellants. Furthermore, the Tribunal noted the principal manufacturer's participation in the Sabka Vishwas Scheme (SVLDRS), which had already discharged duty on the goods. Consequently, the Tribunal allowed the appeal with consequential relief.
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