TNMM comparability using audited accounts and working-capital adjustments can eliminate unwarranted transfer-pricing additions where verified margins ...
Gross-profit additions on disputed purchases require reasoned appellate determination; disclosed claims alone do not support inaccurate-particulars pe...
Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barr...
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursement...
Palmolein classification defeated the crude-oil concession; material misdeclaration sustained recovery and confiscation, while separate false-document...
DGFT regularisation of EPCG imports after payment of duty and interest rendered confiscation of the imported goods and penalty for non-fulfilment of export obligation unsustainable. The Tribunal allowed relief from confiscation and penalty while leaving the unchallenged duty and interest liability intact. Duty foregone on capital goods imported under an EPCG licence must be computed using the assessable value declared in the Bill of Entry, rather than the value stated in the licence.
DGFT regularisation of EPCG imports after payment of duty and interest rendered confiscation of the imported goods and penalty for non-fulfilment of export obligation unsustainable. The Tribunal allowed relief from confiscation and penalty while leaving the unchallenged duty and interest liability intact. Duty foregone on capital goods imported under an EPCG licence must be computed using the assessable value declared in the Bill of Entry, rather than the value stated in the licence.
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