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...
Penalty u/s 112 - EPCG - When the notification itself provides for a situation where an importer is not able to fulfil the obligation, the question of violation of conditions of notification does not arise - AT
Penalty u/s 112 - EPCG - When the notification itself provides for a situation where an importer is not able to fulfil the obligation, the question of violation of conditions of notification does not arise - AT
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