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...
Coin blanks of copper alloys/strips of copper/coils of zinc & nickel to be classified under CETH 74094000 as copper plates, sheets and strips exceeding 0.15mm thickness of copper nickel base alloys or under 7419. Coin blanks cannot be classified along with plates and strips as they have distinctive shape, size, character and use; plates and strips are raw materials while coin blanks are near-finished manufactured items. Copper strips and coin blanks constitute similar goods to avail benefit under Para 6.8(a) of Foreign Trade Policy, 2009-14. Education Cess cannot be charged twice after being added to Customs duties. No penalty can be imposed u/r 25 of Central Excise Rules as the issue pertains to legal interpretation, and advance rulings favored the appellants on classification. Appeal allowed in part.
Coin blanks of copper alloys/strips of copper/coils of zinc & nickel to be classified under CETH 74094000 as copper plates, sheets and strips exceeding 0.15mm thickness of copper nickel base alloys or under 7419. Coin blanks cannot be classified along with plates and strips as they have distinctive shape, size, character and use; plates and strips are raw materials while coin blanks are near-finished manufactured items. Copper strips and coin blanks constitute similar goods to avail benefit under Para 6.8(a) of Foreign Trade Policy, 2009-14. Education Cess cannot be charged twice after being added to Customs duties. No penalty can be imposed u/r 25 of Central Excise Rules as the issue pertains to legal interpretation, and advance rulings favored the appellants on classification. Appeal allowed in part.
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