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...
DFIA scheme - Import of ‘saffron’/ ‘saffron pushali B’ - ‘food flavour’ and ‘food colour’ in edible goods - actual use condition and disclosure - The Tribunal criticized the Customs authority for overstepping its jurisdiction by interpreting the Foreign Trade Policy and the exemptions therein. The Tribunal asserted that the Customs authority's role is limited to tax collection and prohibition enforcement, not policy interpretation. - The Tribunal highlighted that 'actual use' conditions for imports should not extend to post-exportation stages unless explicitly stated.
DFIA scheme - Import of ‘saffron’/ ‘saffron pushali B’ - ‘food flavour’ and ‘food colour’ in edible goods - actual use condition and disclosure - The Tribunal criticized the Customs authority for overstepping its jurisdiction by interpreting the Foreign Trade Policy and the exemptions therein. The Tribunal asserted that the Customs authority's role is limited to tax collection and prohibition enforcement, not policy interpretation. - The Tribunal highlighted that 'actual use' conditions for imports should not extend to post-exportation stages unless explicitly stated.
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