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...
Customs Act, 1962 - Penalty levied on appellant as co-noticee for principal violator's diversion of duty-free imported goods under DEEC scheme to local market without fulfilling export obligation. Appellant's relationship with principal violator not sufficient evidence of knowledge about modus operandi. Appellant severed ties with partnership firm after payment issue. Commissioner's order imposing penalty set aside by Appellate Tribunal due to lack of corroborative evidence against appellant.
Customs Act, 1962 - Penalty levied on appellant as co-noticee for principal violator's diversion of duty-free imported goods under DEEC scheme to local market without fulfilling export obligation. Appellant's relationship with principal violator not sufficient evidence of knowledge about modus operandi. Appellant severed ties with partnership firm after payment issue. Commissioner's order imposing penalty set aside by Appellate Tribunal due to lack of corroborative evidence against appellant.
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