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...
Duty demand u/s 11D - sale of goods as inclusive of duty - appellant is not the manufacturer of the goods and has not paid any excise duty. They are only trading and working with the profit on the discount extended by the manufacturer on the price fixed by NPPA - No demand - AT
Duty demand u/s 11D - sale of goods as inclusive of duty - appellant is not the manufacturer of the goods and has not paid any excise duty. They are only trading and working with the profit on the discount extended by the manufacturer on the price fixed by NPPA - No demand - AT
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