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...
Recovery of drawback under Rules 16 and 16A of the 1995 Drawback Rules was held impermissible after the 2017 Drawback Rules came into force, because the repeal and saving provision in rule 20(2) did not preserve such proceedings and the show cause notice was issued only after the new rules operated. Denial of All Industry Rate drawback was rejected where the export consignments were assessed, Let Export Orders were issued, and drawback was granted; alleged fake procurement invoices could not defeat the claim, and the recorded statement was inadmissible without compliance with section 138B. Confiscation of goods already exported was also set aside, and penalties under sections 114 and 114AA on the exporter and partner could not survive.
Recovery of drawback under Rules 16 and 16A of the 1995 Drawback Rules was held impermissible after the 2017 Drawback Rules came into force, because the repeal and saving provision in rule 20(2) did not preserve such proceedings and the show cause notice was issued only after the new rules operated. Denial of All Industry Rate drawback was rejected where the export consignments were assessed, Let Export Orders were issued, and drawback was granted; alleged fake procurement invoices could not defeat the claim, and the recorded statement was inadmissible without compliance with section 138B. Confiscation of goods already exported was also set aside, and penalties under sections 114 and 114AA on the exporter and partner could not survive.
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