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...
Benefit of Notification No. 21/2002 - classification - Once the tariff heading changed and the High Alumina Refractory Cement was classified under other hydraulic cement, no doubt the question of the product which is known in the trade as High Alumina Refractory Cement would be under the relevant heading in the tariff and there cannot be any dispute on this aspect. - AT
Benefit of Notification No. 21/2002 - classification - Once the tariff heading changed and the High Alumina Refractory Cement was classified under other hydraulic cement, no doubt the question of the product which is known in the trade as High Alumina Refractory Cement would be under the relevant heading in the tariff and there cannot be any dispute on this aspect. - AT
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