Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
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...
Foreign remittance compliance turned on whether the appellant could prove import through valid Bills of Entry linked to the impugned remittances and asserted high sea sale documents. The Tribunal found that the Bill of Entry related to the same Bill of Lading, but the handwritten notation relied on to show coverage of all three remittances was partly illegible and not shown to have been made by authorised personnel. Customs records did not establish duty on the full amount claimed, and RBI confirmed that the relevant Bills of Entry had not been submitted to the Authorised Dealer. Contravention was therefore sustained, but the penalty was reduced and the pre-deposit adjusted.
Foreign remittance compliance turned on whether the appellant could prove import through valid Bills of Entry linked to the impugned remittances and asserted high sea sale documents. The Tribunal found that the Bill of Entry related to the same Bill of Lading, but the handwritten notation relied on to show coverage of all three remittances was partly illegible and not shown to have been made by authorised personnel. Customs records did not establish duty on the full amount claimed, and RBI confirmed that the relevant Bills of Entry had not been submitted to the Authorised Dealer. Contravention was therefore sustained, but the penalty was reduced and the pre-deposit adjusted.
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