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 export goods - Iron Ore Fines - transaction value - FOB price - Export duty - The appellant contested this, arguing that unless the Revenue disputes the transaction value with corroborative evidence, it should be considered valid, citing relevant case laws. The Tribunal concurred, emphasizing that the Revenue had not doubted the transaction value and had not followed sequential valuation rules before adopting contemporaneous values. As the Revenue did not contest the Adjudicating Authority's findings, the transaction value's correctness was upheld, and the appeal was allowed.
Valuation of export goods - Iron Ore Fines - transaction value - FOB price - Export duty - The appellant contested this, arguing that unless the Revenue disputes the transaction value with corroborative evidence, it should be considered valid, citing relevant case laws. The Tribunal concurred, emphasizing that the Revenue had not doubted the transaction value and had not followed sequential valuation rules before adopting contemporaneous values. As the Revenue did not contest the Adjudicating Authority's findings, the transaction value's correctness was upheld, and the appeal was allowed.
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