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...
Misdeclaration and undervaluation of the goods - redemption fine and penalty - The appellants declared the goods as 'Stock Lot Polyester Knitted Fabrics', but the department claimed they were knitted fabrics with one side brushing, leading to misdeclaration and undervaluation. The Tribunal found that the expert witness lacked sufficient knowledge about the brushing process, undermining the department's claim. Additionally, the enhancement of value based on NIDB data, without providing details to the appellant or mentioning it in the SCN, was deemed improper. Consequently, the Tribunal set aside the impugned orders, allowing the appeals with consequential relief.
Misdeclaration and undervaluation of the goods - redemption fine and penalty - The appellants declared the goods as 'Stock Lot Polyester Knitted Fabrics', but the department claimed they were knitted fabrics with one side brushing, leading to misdeclaration and undervaluation. The Tribunal found that the expert witness lacked sufficient knowledge about the brushing process, undermining the department's claim. Additionally, the enhancement of value based on NIDB data, without providing details to the appellant or mentioning it in the SCN, was deemed improper. Consequently, the Tribunal set aside the impugned orders, allowing the appeals with consequential relief.
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