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...
Re-export of even after the expiry of the warehousing period - Due to COVID-19 pandemic, the appellants were unable to proceed with their construction project and clear the goods for home consumption - In light of the circumstances, including the COVID-19 pandemic and the appellant's efforts to re-export the goods, the Tribunal found merit in the appellant's arguments. They emphasized the need for flexibility in such exceptional situations and cited the judgement of the Hon’ble Supreme Court regarding the extension of limitation period. Consequently, the Tribunal set aside the impugned order and directed the respondent to allow re-export of the goods within a specified period without insisting on payment of duty, interest, fine, or penalty.
Re-export of even after the expiry of the warehousing period - Due to COVID-19 pandemic, the appellants were unable to proceed with their construction project and clear the goods for home consumption - In light of the circumstances, including the COVID-19 pandemic and the appellant's efforts to re-export the goods, the Tribunal found merit in the appellant's arguments. They emphasized the need for flexibility in such exceptional situations and cited the judgement of the Hon’ble Supreme Court regarding the extension of limitation period. Consequently, the Tribunal set aside the impugned order and directed the respondent to allow re-export of the goods within a specified period without insisting on payment of duty, interest, fine, or penalty.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4819 
Join Channel 
