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...
Provisional release of seized imported goods was directed on conditional terms because the matter was still at the seizure-memo stage and the request was limited to interim relief. The Court followed earlier writ orders on similar facts and required release subject to payment of the quantified enhanced duty, furnishing of bank guarantee to the extent directed, and maintenance of transaction details if the goods were subsequently supplied after release. Customs was left free to continue adjudication in accordance with law, and the conditional release order was expressly stated not to influence the merits of that adjudication.
Provisional release of seized imported goods was directed on conditional terms because the matter was still at the seizure-memo stage and the request was limited to interim relief. The Court followed earlier writ orders on similar facts and required release subject to payment of the quantified enhanced duty, furnishing of bank guarantee to the extent directed, and maintenance of transaction details if the goods were subsequently supplied after release. Customs was left free to continue adjudication in accordance with law, and the conditional release order was expressly stated not to influence the merits of that adjudication.
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