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...
Valuation - Export of Carpets and threading bars - Mis-declaration of description and value - The Tribunal found that while the carpets were misdeclared and subject to confiscation, the threading bars were not misdeclared. The redetermined value was set aside due to lack of evidence from the department to counter procurement documents provided by the respondent. The reduction of redemption fine and penalty was partially upheld considering the admitted misdeclaration by the respondent.
Valuation - Export of Carpets and threading bars - Mis-declaration of description and value - The Tribunal found that while the carpets were misdeclared and subject to confiscation, the threading bars were not misdeclared. The redetermined value was set aside due to lack of evidence from the department to counter procurement documents provided by the respondent. The reduction of redemption fine and penalty was partially upheld considering the admitted misdeclaration by the respondent.
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