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...
Where imported goods are supported by Certificates of Origin issued by the designated authority of the exporting country, any reasonable doubt about authenticity or origin particulars must be addressed through the retroactive verification mechanism under Rule 15 of Annexure B to the Interim Rules of Origin. If the importing authority questions the value addition shown in the certificate, it must seek verification from the issuing authority in Thailand rather than rely only on domestic statements or collected material. Because the prescribed verification procedure was not followed, the notice and the order denying preferential tariff concession were contrary to the Rules, and the exemption denial, consequential demands and penalties were set aside.
Where imported goods are supported by Certificates of Origin issued by the designated authority of the exporting country, any reasonable doubt about authenticity or origin particulars must be addressed through the retroactive verification mechanism under Rule 15 of Annexure B to the Interim Rules of Origin. If the importing authority questions the value addition shown in the certificate, it must seek verification from the issuing authority in Thailand rather than rely only on domestic statements or collected material. Because the prescribed verification procedure was not followed, the notice and the order denying preferential tariff concession were contrary to the Rules, and the exemption denial, consequential demands and penalties were set aside.
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