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...
Cylinders imported without valid PESO certificate, violating Rules 31 and 32 of Gas Cylinder Rules, 2016. Goods confiscated u/s 111(d) of Customs Act, 1962. Petitioner argued reasons attributable to PESO Authorities, sought relief from confiscation and penalty. Respondents contended goods arrived before incorrect PESO certificate date, justifying redemption fine and penalty. HC ordered provisional release of cylinders worth Rs. 31 lakhs on furnishing bonds and paying Rs. 2,00,000/- without prejudice, subject to adjudication of show cause notice. Petitioner granted liberty to file reply to notice by 30 October 2024. Payment abides by conclusion of adjudication proceedings.
Cylinders imported without valid PESO certificate, violating Rules 31 and 32 of Gas Cylinder Rules, 2016. Goods confiscated u/s 111(d) of Customs Act, 1962. Petitioner argued reasons attributable to PESO Authorities, sought relief from confiscation and penalty. Respondents contended goods arrived before incorrect PESO certificate date, justifying redemption fine and penalty. HC ordered provisional release of cylinders worth Rs. 31 lakhs on furnishing bonds and paying Rs. 2,00,000/- without prejudice, subject to adjudication of show cause notice. Petitioner granted liberty to file reply to notice by 30 October 2024. Payment abides by conclusion of adjudication proceedings.
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