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...
Section 112(a) and 112(b) were held to cover both abetment or omission rendering goods liable to confiscation and possession or dealing with goods known or believed to be liable to confiscation, so the show-cause notice was valid where it specified the petitioner's role in smuggling gold paste without declaration. The Court rejected the objection based on non-specification of the precise clause, holding that the notice gave adequate particulars and was answered on merits. Smuggled gold imported in breach of customs restrictions was treated as prohibited goods, so penalty under Section 112(i) was also sustained. The writ petition was dismissed and the penalty order upheld.
Section 112(a) and 112(b) were held to cover both abetment or omission rendering goods liable to confiscation and possession or dealing with goods known or believed to be liable to confiscation, so the show-cause notice was valid where it specified the petitioner's role in smuggling gold paste without declaration. The Court rejected the objection based on non-specification of the precise clause, holding that the notice gave adequate particulars and was answered on merits. Smuggled gold imported in breach of customs restrictions was treated as prohibited goods, so penalty under Section 112(i) was also sustained. The writ petition was dismissed and the penalty order upheld.
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