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...
Advance ruling jurisdiction is barred where the question raised has already been conclusively decided by a Court, because the authority cannot re-adjudicate a settled issue or create conflicting classifications. Applying that principle, the Authority held that the classification of roasted areca nuts was already determined by the Madras High Court under Heading 2008, and the applicant showed no change in the goods' nature, composition or processing. Mere renumbering or substitution of the tariff sub-heading after later legislation did not create a fresh classification question. The application was therefore not maintainable and was rejected as covered by binding judicial precedent.
Advance ruling jurisdiction is barred where the question raised has already been conclusively decided by a Court, because the authority cannot re-adjudicate a settled issue or create conflicting classifications. Applying that principle, the Authority held that the classification of roasted areca nuts was already determined by the Madras High Court under Heading 2008, and the applicant showed no change in the goods' nature, composition or processing. Mere renumbering or substitution of the tariff sub-heading after later legislation did not create a fresh classification question. The application was therefore not maintainable and was rejected as covered by binding judicial precedent.
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