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...
Classification dispute over imported goods - whether categorized as freely importable silver jewelry or restricted under ITC (HS) Code 71069210. Apex court reiterated writ jurisdiction under Articles 32 and 226 is extraordinary, equitable, and discretionary, requiring petitioner to approach court with clean hands, candid disclosure without concealment. Petitioner made false averments about being a registered partnership firm, misleading the court. Held that petitioner abused legal process, not entitled to extraordinary relief. Petition dismissed for lack of candor and suppression of facts.
Classification dispute over imported goods - whether categorized as freely importable silver jewelry or restricted under ITC (HS) Code 71069210. Apex court reiterated writ jurisdiction under Articles 32 and 226 is extraordinary, equitable, and discretionary, requiring petitioner to approach court with clean hands, candid disclosure without concealment. Petitioner made false averments about being a registered partnership firm, misleading the court. Held that petitioner abused legal process, not entitled to extraordinary relief. Petition dismissed for lack of candor and suppression of facts.
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