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...
The appellate tribunal held that there was no dispute regarding the transferability of the DFRC license. The appellants were unaware of the license holder after selling it, and it was the buyer's responsibility to register at the port of export and apply for Telegraphic Release Advice (TRA) as per the relevant public notice. The facts did not establish any mischief or wrongdoing by the appellants concerning the alleged change claimed by the revenue authorities. Since the appellants' role was unclear, imposing a penalty on them was not in accordance with the law. Consequently, the impugned orders were set aside, the penalty imposed on the appellants was deleted, and the appeal was allowed.
The appellate tribunal held that there was no dispute regarding the transferability of the DFRC license. The appellants were unaware of the license holder after selling it, and it was the buyer's responsibility to register at the port of export and apply for Telegraphic Release Advice (TRA) as per the relevant public notice. The facts did not establish any mischief or wrongdoing by the appellants concerning the alleged change claimed by the revenue authorities. Since the appellants' role was unclear, imposing a penalty on them was not in accordance with the law. Consequently, the impugned orders were set aside, the penalty imposed on the appellants was deleted, and the appeal was allowed.
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