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...
Amendment of Invoice – Demand of differential duty – Appellant being EOU eligible to import goods without payment of duty and considering terms of payment and procurement certificate issued by Divisional authorities covering full value, there is no mis-declaration or malafide intention for evasion of duty - AT
Amendment of Invoice – Demand of differential duty – Appellant being EOU eligible to import goods without payment of duty and considering terms of payment and procurement certificate issued by Divisional authorities covering full value, there is no mis-declaration or malafide intention for evasion of duty - AT
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