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...
Misdeclaration of value was not established because the Chartered Engineer's valuation was given casually, no supporting material or comparable imports were produced, and there was no evidence that the importer paid more than the invoice price; the re-determination of assessable value was therefore unsustainable. The goods also could not be classified as incomplete or unfinished computer systems, since the authorities recorded no reasons, the descriptions "computer cabinet cases" and "bare bone systems" were used interchangeably, and a cabinet case with only a motherboard and fan did not attain the essential character of a computer without a CPU. The appeals were allowed and the impugned orders were set aside.
Misdeclaration of value was not established because the Chartered Engineer's valuation was given casually, no supporting material or comparable imports were produced, and there was no evidence that the importer paid more than the invoice price; the re-determination of assessable value was therefore unsustainable. The goods also could not be classified as incomplete or unfinished computer systems, since the authorities recorded no reasons, the descriptions "computer cabinet cases" and "bare bone systems" were used interchangeably, and a cabinet case with only a motherboard and fan did not attain the essential character of a computer without a CPU. The appeals were allowed and the impugned orders were set aside.
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