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...
Recovery of duty drawback granted earlier with interest - The petitioner claimed non-receipt of the show cause notice and argued that the sale proceeds had been realized, citing the availability of the Bank Realization Certificate online. However, the petitioner did not produce the certificate during the enquiry, leading to the issuance of the impugned order. The High Court, while acknowledging the petitioner's arguments, emphasized the importance of producing relevant documents during the enquiry process. Consequently, the Court remanded the matter back to the authorities.
Recovery of duty drawback granted earlier with interest - The petitioner claimed non-receipt of the show cause notice and argued that the sale proceeds had been realized, citing the availability of the Bank Realization Certificate online. However, the petitioner did not produce the certificate during the enquiry, leading to the issuance of the impugned order. The High Court, while acknowledging the petitioner's arguments, emphasized the importance of producing relevant documents during the enquiry process. Consequently, the Court remanded the matter back to the authorities.
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