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...
Discretionary Power - The adjudicating authority had used his discretionary power to come to reasoned conclusion not to confiscate the goods - the decision cannot be called in question in the facts and circumstances of this case - AT
Discretionary Power - The adjudicating authority had used his discretionary power to come to reasoned conclusion not to confiscate the goods - the decision cannot be called in question in the facts and circumstances of this case - AT
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