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...
Revenue authorities, on receipt of classification list, did not direct the appellant to go for the drawal of the samples and get the same tested in order to ascertain the correct classification of the product - revenue authorities now cannot turnaround and allege that there was suppression, mis-statement on the part of appellant - AT
Revenue authorities, on receipt of classification list, did not direct the appellant to go for the drawal of the samples and get the same tested in order to ascertain the correct classification of the product - revenue authorities now cannot turnaround and allege that there was suppression, mis-statement on the part of appellant - AT
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