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...
Refund claim u/r 5 of unutilized Cenvat Credit - appellant has debited the amount in the Cenvat credit account on 01.07.2003 i.e. on the date of filing of the refund claim satisfied the said condition. The fact that the details of the same have not been reflected in the ER-2 or in the application filed will not make any difference - AT
Refund claim u/r 5 of unutilized Cenvat Credit - appellant has debited the amount in the Cenvat credit account on 01.07.2003 i.e. on the date of filing of the refund claim satisfied the said condition. The fact that the details of the same have not been reflected in the ER-2 or in the application filed will not make any difference - AT
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