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...
Levy of safeguard duty - Determination of effective date and time of implementation of Notification - The appellant argued that the notification was only effective from its publication date in the Official Gazette, which was 24.02.2013. The Tribunal considered various judicial precedents and concluded that a notification becomes effective only upon its publication in the Official Gazette. Since the appellant’s goods were imported before the publication date, the safeguard duty could not be imposed.
Levy of safeguard duty - Determination of effective date and time of implementation of Notification - The appellant argued that the notification was only effective from its publication date in the Official Gazette, which was 24.02.2013. The Tribunal considered various judicial precedents and concluded that a notification becomes effective only upon its publication in the Official Gazette. Since the appellant’s goods were imported before the publication date, the safeguard duty could not be imposed.
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