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. 67/95 – Captive consumption - prior to 01/06/2001, there was no provision in Notification No.67/95-CE for discharge of a sum @8% on the value of the final products which were chargeable to ‘nil' rate of duty or exempted from payment of duty - however on the period of limitation demand set aside - AT
Benefit of Notification No. 67/95 – Captive consumption - prior to 01/06/2001, there was no provision in Notification No.67/95-CE for discharge of a sum @8% on the value of the final products which were chargeable to ‘nil' rate of duty or exempted from payment of duty - however on the period of limitation demand set aside - AT
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