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...
Appellate Tribunal ruling on rejection of transaction value and re-determination of imported goods' value. Lack of justification for rejecting declared values under Valuation Rules. Inadequate details on Bills of Entry for identical or similar goods used for re-determination. No comparison of features between imported goods and goods whose values were adopted. Re-determination of values, demand for differential duty, confiscation, and penalties set aside for specific goods. Penalty u/s 114AA reduced. Matter remanded for recalculation. Partial allowance of appeal.
Appellate Tribunal ruling on rejection of transaction value and re-determination of imported goods' value. Lack of justification for rejecting declared values under Valuation Rules. Inadequate details on Bills of Entry for identical or similar goods used for re-determination. No comparison of features between imported goods and goods whose values were adopted. Re-determination of values, demand for differential duty, confiscation, and penalties set aside for specific goods. Penalty u/s 114AA reduced. Matter remanded for recalculation. Partial allowance of appeal.
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