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 appellant sought stay of the impugned order citing violation of principles of natural justice due to denial of cross-examination of witnesses in quasi-judicial proceedings related to mis-declaration of quantity and value of goods. The Tribunal held that the appellant repeatedly delayed filing a reply to the show-cause notice and sought cross-examination on flimsy grounds without specifying valid reasons. Relying on Supreme Court precedent, the Tribunal ruled that cross-examination was unwarranted as the officers merely prepared documents based on evidence retrieved, and the appellant failed to contest the statements with specific reasons. Consequently, the appeal was dismissed for lack of merit.
The appellant sought stay of the impugned order citing violation of principles of natural justice due to denial of cross-examination of witnesses in quasi-judicial proceedings related to mis-declaration of quantity and value of goods. The Tribunal held that the appellant repeatedly delayed filing a reply to the show-cause notice and sought cross-examination on flimsy grounds without specifying valid reasons. Relying on Supreme Court precedent, the Tribunal ruled that cross-examination was unwarranted as the officers merely prepared documents based on evidence retrieved, and the appellant failed to contest the statements with specific reasons. Consequently, the appeal was dismissed for lack of merit.
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