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...
Revocation of the Customs Broker Licence - The appellant argued that the license had already been revoked once and reinstated by the Tribunal, making the subsequent revocation unjustified. The Department alleged violations under various provisions of the Customs Act and Customs Brokers Licensing Regulations. However, the Tribunal found no merit in the Department's allegations, highlighting discrepancies in the application of relevant provisions and logistical challenges at the Land Customs Station. Ultimately, the Tribunal ruled in favor of the appellant, setting aside the impugned order and restoring the appellant's license.
Revocation of the Customs Broker Licence - The appellant argued that the license had already been revoked once and reinstated by the Tribunal, making the subsequent revocation unjustified. The Department alleged violations under various provisions of the Customs Act and Customs Brokers Licensing Regulations. However, the Tribunal found no merit in the Department's allegations, highlighting discrepancies in the application of relevant provisions and logistical challenges at the Land Customs Station. Ultimately, the Tribunal ruled in favor of the appellant, setting aside the impugned order and restoring the appellant's license.
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