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 - Bar of limitation - payment of duty was made before issue of SCN - claim of refund was submitted after the SCN was dropped - period of limitation to be computed from the date of final order dropping the demand - HC
Denial of refund claim - Bar of limitation - payment of duty was made before issue of SCN - claim of refund was submitted after the SCN was dropped - period of limitation to be computed from the date of final order dropping the demand - HC
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