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...
The case involved operating a duty-free shop without the required Special Warehouse Licence, leading to illegal sales of duty-free goods. The appellant was initially allocated a smaller space for the shop, but later shifted to a larger space without amending the Licence. However, goods were stored and removed under Customs supervision. The Tribunal found no evidence of illegal activities and directed the Commissioner to restore the original Licence and consider amending it to include the larger space. The appeal was allowed, setting aside the impugned order and remanding the case for further action.
The case involved operating a duty-free shop without the required Special Warehouse Licence, leading to illegal sales of duty-free goods. The appellant was initially allocated a smaller space for the shop, but later shifted to a larger space without amending the Licence. However, goods were stored and removed under Customs supervision. The Tribunal found no evidence of illegal activities and directed the Commissioner to restore the original Licence and consider amending it to include the larger space. The appeal was allowed, setting aside the impugned order and remanding the case for further action.
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