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...
Transmission shafts, gears, gear boxes and allied machine parts manufactured for agricultural machinery were classifiable under Heading 8483, because Note 2(a) to Section XVI required goods specifically covered by a Chapter 84 heading to be classified there even if they were designed for a particular machine. The Tribunal also accepted that amounts reversed under Rule 6(3) on a bona fide exemption belief had to be adjusted against any duty liability, and cum-duty benefit was admissible where no duty was separately collected. The demand, however, was held time-barred: the dispute turned on tariff interpretation, suppression with intent to evade was not proved, and the extended period could not be invoked.
Transmission shafts, gears, gear boxes and allied machine parts manufactured for agricultural machinery were classifiable under Heading 8483, because Note 2(a) to Section XVI required goods specifically covered by a Chapter 84 heading to be classified there even if they were designed for a particular machine. The Tribunal also accepted that amounts reversed under Rule 6(3) on a bona fide exemption belief had to be adjusted against any duty liability, and cum-duty benefit was admissible where no duty was separately collected. The demand, however, was held time-barred: the dispute turned on tariff interpretation, suppression with intent to evade was not proved, and the extended period could not be invoked.
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