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 Appellate Tribunal considered the entitlement to duty exemption u/s N/N. 25/2023-CUS for the import of Lithium Ion Battery under a Transferrable DFIA License. The issue was whether the battery falls under the description of "Automative Battery" as per the license. The respondent argued that the imported Lithium Battery is a type of automotive battery, supported by a certificate from IIT engineers. The Tribunal emphasized the "capability of use" of the battery, not just similarity to other automotive batteries. It upheld that the DFIA scheme allows for broad categorization under "capable of being used in electrical vehicles." The appeal by the Department was dismissed, granting relief to the respondent.
The Appellate Tribunal considered the entitlement to duty exemption u/s N/N. 25/2023-CUS for the import of Lithium Ion Battery under a Transferrable DFIA License. The issue was whether the battery falls under the description of "Automative Battery" as per the license. The respondent argued that the imported Lithium Battery is a type of automotive battery, supported by a certificate from IIT engineers. The Tribunal emphasized the "capability of use" of the battery, not just similarity to other automotive batteries. It upheld that the DFIA scheme allows for broad categorization under "capable of being used in electrical vehicles." The appeal by the Department was dismissed, granting relief to the respondent.
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