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...
Adjudication of show cause notice (SCN) after several year - The tribunal noted the history of duty exemption, litigation, and subsequent duty imposition on resin extraction. It highlighted the stay on duty payment due to court orders, the challenge to the duty imposition, and the subsequent liability post-2019 judgment. - The tribunal found that the show cause notices issued during the litigation period were unsustainable, given the stay on duty payment and subsequent release of duty amounts to buyers. It also criticized the delayed adjudication, citing legal precedents for setting aside belated orders and unreasonable delays.
Adjudication of show cause notice (SCN) after several year - The tribunal noted the history of duty exemption, litigation, and subsequent duty imposition on resin extraction. It highlighted the stay on duty payment due to court orders, the challenge to the duty imposition, and the subsequent liability post-2019 judgment. - The tribunal found that the show cause notices issued during the litigation period were unsustainable, given the stay on duty payment and subsequent release of duty amounts to buyers. It also criticized the delayed adjudication, citing legal precedents for setting aside belated orders and unreasonable delays.
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