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...
CESTAT ruled that gold seizure was unwarranted due to insufficient evidence of foreign origin. Revenue failed to demonstrate reasonable belief under Section 110, while the appellant provided procurement invoices, profit and loss accounts, income tax returns, and GST payment records. The tribunal held the gold confiscation unsustainable, ordered its release to the owner, and vacated associated penalties. The appellate order set aside the original confiscation order, granting complete relief to the appellants and mandating the return of both gold and vehicle.
CESTAT ruled that gold seizure was unwarranted due to insufficient evidence of foreign origin. Revenue failed to demonstrate reasonable belief under Section 110, while the appellant provided procurement invoices, profit and loss accounts, income tax returns, and GST payment records. The tribunal held the gold confiscation unsustainable, ordered its release to the owner, and vacated associated penalties. The appellate order set aside the original confiscation order, granting complete relief to the appellants and mandating the return of both gold and vehicle.
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