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 of interest u/s 11AB - interest on reversal amount of cenvat credit - appellant cannot take the shelter of Rule-6(3A)(e) of the CCR to avoid payment of interest. Once a monthly payment mode is prescribed the same is required to be discharged by the appellant. - AT
Demand of interest u/s 11AB - interest on reversal amount of cenvat credit - appellant cannot take the shelter of Rule-6(3A)(e) of the CCR to avoid payment of interest. Once a monthly payment mode is prescribed the same is required to be discharged by the appellant. - AT
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