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...
Impugned order quashing levy of penalty for transportation of goods upheld. Power of detention or seizure can only be exercised when goods lack genuine documents under Act. Genuineness of documents not disputed. Allegation that prescribed documents not produced unsupported. Once accompanying documents found genuine, goods should not have been seized. Impugned order dated 06.03.2024 quashed, petition allowed.
Impugned order quashing levy of penalty for transportation of goods upheld. Power of detention or seizure can only be exercised when goods lack genuine documents under Act. Genuineness of documents not disputed. Allegation that prescribed documents not produced unsupported. Once accompanying documents found genuine, goods should not have been seized. Impugned order dated 06.03.2024 quashed, petition allowed.
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