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...
Denial of refund claim - in the second proceedings original authority has found that a portion of the refund claim was time-barred - once all the refund claims and their fate had attained finality in the order of the Commissioner (Appeals), no further action could have been taken - AT
Denial of refund claim - in the second proceedings original authority has found that a portion of the refund claim was time-barred - once all the refund claims and their fate had attained finality in the order of the Commissioner (Appeals), no further action could have been taken - AT
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