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...
EPCG Scheme - Benefit of an EXIM scheme - Non fulfilment of the export obligations - The High Court examined the clauses of the bonds executed by the appellant and concluded that the penalty clause in the indemnity cum guarantee bond was valid. This clause mandated payment of 24% interest per annum on the duty saved in case of default. The court differentiated between this penalty and the interest claimed by the Customs Department, affirming the appellant's liability for the penalty outlined in the bonds.
EPCG Scheme - Benefit of an EXIM scheme - Non fulfilment of the export obligations - The High Court examined the clauses of the bonds executed by the appellant and concluded that the penalty clause in the indemnity cum guarantee bond was valid. This clause mandated payment of 24% interest per annum on the duty saved in case of default. The court differentiated between this penalty and the interest claimed by the Customs Department, affirming the appellant's liability for the penalty outlined in the bonds.
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