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...
Denial of refund claim - Unjust enrichment - returned of excess duty through debit / credit Notes - appellant admittedly accounted for the said amount as ‘receivable’ in the balance sheet, it is a sufficient evidence to hold that incidence of duty has not been passed on - AT
Denial of refund claim - Unjust enrichment - returned of excess duty through debit / credit Notes - appellant admittedly accounted for the said amount as ‘receivable’ in the balance sheet, it is a sufficient evidence to hold that incidence of duty has not been passed on - AT
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