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...
Reusable metal containers owned by an overseas supplier and imported with raw material were not treated as separately dutiable goods under the Customs Act, 1962; applying the Supreme Court principle in Chairman, Board of Trustees, Cochin Port Trust v. Arebee Star Maritime Agencies, the Tribunal held that duty could not be demanded again on the containers. Under section 14 read with Rule 10(1) of the Customs Valuation Rules, 2007, only packing cost actually incurred or payable by the importer could be included, and the rental value of the packing material was already reflected in the CIF value of the imported synthetic rubber. The reassessment, including interest and penalties, was set aside.
Reusable metal containers owned by an overseas supplier and imported with raw material were not treated as separately dutiable goods under the Customs Act, 1962; applying the Supreme Court principle in Chairman, Board of Trustees, Cochin Port Trust v. Arebee Star Maritime Agencies, the Tribunal held that duty could not be demanded again on the containers. Under section 14 read with Rule 10(1) of the Customs Valuation Rules, 2007, only packing cost actually incurred or payable by the importer could be included, and the rental value of the packing material was already reflected in the CIF value of the imported synthetic rubber. The reassessment, including interest and penalties, was set aside.
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