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...
Refund claim - unjust enrichment - Initially claim filed without challenging the self-assessed Bills of Entry - During the appeal process, the appellant sought to amend the bills of entry, which was initially rejected but later allowed by the High Court. The High Court directed the amendment of bills of entry to reflect the correct duty rate, enabling the appellant to seek a refund of excess duty paid. Following the High Court's directive, the Adjudicating Authority granted the refund, stating that there was no unjust enrichment based on evidence provided.
Refund claim - unjust enrichment - Initially claim filed without challenging the self-assessed Bills of Entry - During the appeal process, the appellant sought to amend the bills of entry, which was initially rejected but later allowed by the High Court. The High Court directed the amendment of bills of entry to reflect the correct duty rate, enabling the appellant to seek a refund of excess duty paid. Following the High Court's directive, the Adjudicating Authority granted the refund, stating that there was no unjust enrichment based on evidence provided.
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