Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
The High Court held that the appeals were maintainable as the show cause notice issued by the Adjudicating Authority raised issues pertaining to mis-declaration of description and value addition to wrongly claim benefit under the replenishment scheme, applicability of Notification No. 57/2000-Customs and Circular No. 27/206-Customs, and the Foreign Trade Policy 2015-20. The Court found no substantial questions of law arising for consideration, as the demand for duty on the quantum of gold received under the replenishment scheme was not disputed, and the findings of fact were properly appreciated based on the available record. Consequently, the appeals were dismissed.
The High Court held that the appeals were maintainable as the show cause notice issued by the Adjudicating Authority raised issues pertaining to mis-declaration of description and value addition to wrongly claim benefit under the replenishment scheme, applicability of Notification No. 57/2000-Customs and Circular No. 27/206-Customs, and the Foreign Trade Policy 2015-20. The Court found no substantial questions of law arising for consideration, as the demand for duty on the quantum of gold received under the replenishment scheme was not disputed, and the findings of fact were properly appreciated based on the available record. Consequently, the appeals were dismissed.
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