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 dismissed the appeal, upholding penalties against the appellant for customs duty evasion. The court found the appellant's claims of merely lending his Importer Exporter Code (IEC) to be unsubstantiated. Despite alleging lack of cross-examination opportunity, the court determined the appellant deliberately attempted to evade facts and was complicit with Mr. Rajat Arora in fraudulent import transactions. The appellant was deemed responsible for misuse of his IEC registration and acting in concert with the co-conspirator. Consequently, the original penalties and amounts imposed were confirmed, and the appeal was rejected.
HC dismissed the appeal, upholding penalties against the appellant for customs duty evasion. The court found the appellant's claims of merely lending his Importer Exporter Code (IEC) to be unsubstantiated. Despite alleging lack of cross-examination opportunity, the court determined the appellant deliberately attempted to evade facts and was complicit with Mr. Rajat Arora in fraudulent import transactions. The appellant was deemed responsible for misuse of his IEC registration and acting in concert with the co-conspirator. Consequently, the original penalties and amounts imposed were confirmed, and the appeal was rejected.
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