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...
Extended period of limitation - jurisdiction - dispute regarding valuation was settled by the larger bench of tribunal - Tribunal rightly turned down the demand of duty prior to the period of one year from the date of issuance of show cause notice dated 9-11-2009, holding the same to have been hit by the law of limitation - HC
Extended period of limitation - jurisdiction - dispute regarding valuation was settled by the larger bench of tribunal - Tribunal rightly turned down the demand of duty prior to the period of one year from the date of issuance of show cause notice dated 9-11-2009, holding the same to have been hit by the law of limitation - HC
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