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 of the seized goods - (i) Grey metal powder suspected to be Iridium, (ii) Grey metal powder suspected to be Ruthenium, (iii) Micro SD Memory cards, (iv) Stone beads ('Chaton') and (v) Branded watches - The adjudicating authority arrived at the valuation using various sources such as metal bulletins, NIDB data, purchase invoices, and website details. The Appellate Tribunal found the valuation to be appropriate except for Ruthenium, where it disagreed with the method used by the adjudicating authority. The Tribunal determined the value of Ruthenium at Rs. 3,00,000 per kg, which was within the range identified by the authority. Accordingly, the duty payable by the appellants was re-quantified based on the revised valuation.
Valuation of the seized goods - (i) Grey metal powder suspected to be Iridium, (ii) Grey metal powder suspected to be Ruthenium, (iii) Micro SD Memory cards, (iv) Stone beads ('Chaton') and (v) Branded watches - The adjudicating authority arrived at the valuation using various sources such as metal bulletins, NIDB data, purchase invoices, and website details. The Appellate Tribunal found the valuation to be appropriate except for Ruthenium, where it disagreed with the method used by the adjudicating authority. The Tribunal determined the value of Ruthenium at Rs. 3,00,000 per kg, which was within the range identified by the authority. Accordingly, the duty payable by the appellants was re-quantified based on the revised valuation.
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