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...
Onus on Revenue to establish imported goods classifiable under Tariff Item 2710 1220 as Natural Gasoline Liquid (NGL) not discharged. Classification of goods as Naphtha under Tariff Item 27101290 declared by appellant held correct. When department fails to discharge burden of proving claimed classification, entire proceeding vitiated. Settled law that if department doesn't discharge onus for classification claim, appellant's declared classification upheld.
Onus on Revenue to establish imported goods classifiable under Tariff Item 2710 1220 as Natural Gasoline Liquid (NGL) not discharged. Classification of goods as Naphtha under Tariff Item 27101290 declared by appellant held correct. When department fails to discharge burden of proving claimed classification, entire proceeding vitiated. Settled law that if department doesn't discharge onus for classification claim, appellant's declared classification upheld.
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