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...
Issuance of Show cause notice beyond normal period of Limitation – recovery of interest on late payment of duty - when no suppression of facts no demand beyond one year - HC
Issuance of Show cause notice beyond normal period of Limitation – recovery of interest on late payment of duty - when no suppression of facts no demand beyond one year - HC
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