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 - Bar of limitation - appellant was not required to pay service tax but they paid the service tax wrongly - provisions of Section 11B of the Central Excise Act, 1944 are not applicable - AT
Refund - Bar of limitation - appellant was not required to pay service tax but they paid the service tax wrongly - provisions of Section 11B of the Central Excise Act, 1944 are not applicable - AT
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