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...
Cenvat credit - if services are utilised by the service provider Cenvat credit can be availed by such service provider and not any other assessee - Credit cannot be allowed - on merit decided against the assessee - however, demand set aside on the ground of period of limitation - AT
Cenvat credit - if services are utilised by the service provider Cenvat credit can be availed by such service provider and not any other assessee - Credit cannot be allowed - on merit decided against the assessee - however, demand set aside on the ground of period of limitation - AT
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