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 CESTAT upheld the appellant's prior ruling that filling toner powder into used cartridges constitutes "manufacture" under the Customs (Import of Goods at Concessional Rate of Duty for Manufacture of Excisable Goods) Rules, 1996. The Tribunal reaffirmed that since the activity qualifies as manufacture, the demand for customs duty, denial of CENVAT credit, and penalty imposed on the appellant were unsustainable. Consequently, the impugned order was set aside, and the appeal was allowed, granting the appellant the benefit of concessional duty.
The CESTAT upheld the appellant's prior ruling that filling toner powder into used cartridges constitutes "manufacture" under the Customs (Import of Goods at Concessional Rate of Duty for Manufacture of Excisable Goods) Rules, 1996. The Tribunal reaffirmed that since the activity qualifies as manufacture, the demand for customs duty, denial of CENVAT credit, and penalty imposed on the appellant were unsustainable. Consequently, the impugned order was set aside, and the appeal was allowed, granting the appellant the benefit of concessional duty.
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