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...
CESTAT AHMEDABAD held that in a case involving undervaluation of timber imports, the burden of proof lies on the authorities to establish duty demand, penalty, and interest. Referring to the Beena Sales Corporation case, where similar evidence was relied upon, the Tribunal found the decision applicable and upheld by the Supreme Court. Consequently, the impugned orders were deemed unsustainable and set aside, with all appeals allowed and consequential relief granted.
CESTAT AHMEDABAD held that in a case involving undervaluation of timber imports, the burden of proof lies on the authorities to establish duty demand, penalty, and interest. Referring to the Beena Sales Corporation case, where similar evidence was relied upon, the Tribunal found the decision applicable and upheld by the Supreme Court. Consequently, the impugned orders were deemed unsustainable and set aside, with all appeals allowed and consequential relief granted.
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