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...
Non-submission of country-of-origin certificate resulted in denial of concessional rate of Basic Customs Duty under ASEAN FTA Preferential Tariff Agreement for steaming (non-coking) coal in bulk. Alteration/correction in the certificate did not satisfy provisions of operational certification procedures. Denying substantial benefits for technical errors would be unjust. Revenue doubted authenticity of certificate due to correction and date discrepancy, but provided no concrete proof. Procedure to check doubts regarding certificate was not followed. Impugned order set aside, appeals allowed by Appellate Tribunal.
Non-submission of country-of-origin certificate resulted in denial of concessional rate of Basic Customs Duty under ASEAN FTA Preferential Tariff Agreement for steaming (non-coking) coal in bulk. Alteration/correction in the certificate did not satisfy provisions of operational certification procedures. Denying substantial benefits for technical errors would be unjust. Revenue doubted authenticity of certificate due to correction and date discrepancy, but provided no concrete proof. Procedure to check doubts regarding certificate was not followed. Impugned order set aside, appeals allowed by Appellate Tribunal.
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