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Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
The case involved a dispute over unjust enrichment where the appellant was required to prove that customers received machines/equipment as invoiced. The Revenue failed to investigate with customers or transporters. Goods seized by Revenue were linked to the invoices. The appellant did not confirm clearance of goods. The Commissioner(Appeals) approved a refund, finding the appellant paid duty twice. The order was upheld, dismissing Revenue's appeal. The issue of unjust enrichment was referred for further verification.
The case involved a dispute over unjust enrichment where the appellant was required to prove that customers received machines/equipment as invoiced. The Revenue failed to investigate with customers or transporters. Goods seized by Revenue were linked to the invoices. The appellant did not confirm clearance of goods. The Commissioner(Appeals) approved a refund, finding the appellant paid duty twice. The order was upheld, dismissing Revenue's appeal. The issue of unjust enrichment was referred for further verification.
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