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...
Refund of SAD - commissioner (appeals) is not correct in denying the refund by observing that, as the amount of SAD has shown as recoverable only after the sale takes place - refund allowed - AT
Refund of SAD - commissioner (appeals) is not correct in denying the refund by observing that, as the amount of SAD has shown as recoverable only after the sale takes place - refund allowed - AT
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