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...
Demand u/s 11A - Extended period of limitation - there was a general practice in the trade to claim the benefit of exemption - Appellants can not be said to have any malafide intention if the same benefit was availed by them which was also being availed by similarly placed manufacturer- AT
Demand u/s 11A - Extended period of limitation - there was a general practice in the trade to claim the benefit of exemption - Appellants can not be said to have any malafide intention if the same benefit was availed by them which was also being availed by similarly placed manufacturer- AT
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