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...
HC found detention of vehicle and goods under Section 129 was improper. Physical verification confirmed correct quantity and weight of goods against three invoices, with no discrepancy in broad product classifications. Inspecting authority exceeded scope by scrutinizing detailed specifications (pipe size, shutter, TMT Bar dimensions) not required in invoices. While product classification issues could be addressed in separate adjudication proceedings, current detention was unwarranted as there was no evidence of tax evasion or fact suppression. Court ordered release of vehicle and goods within four days of order service. Matter disposed with directive to authorities to comply with release order.
HC found detention of vehicle and goods under Section 129 was improper. Physical verification confirmed correct quantity and weight of goods against three invoices, with no discrepancy in broad product classifications. Inspecting authority exceeded scope by scrutinizing detailed specifications (pipe size, shutter, TMT Bar dimensions) not required in invoices. While product classification issues could be addressed in separate adjudication proceedings, current detention was unwarranted as there was no evidence of tax evasion or fact suppression. Court ordered release of vehicle and goods within four days of order service. Matter disposed with directive to authorities to comply with release order.
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