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...
Duty demand - revenue neutrality - since the goods were cleared to sister concern whatever duty payable and availed as credit to their own unit hence entire exercise would be revenue neutrality - if the ultimate exercise benefited the Revenue by collection of duty and in that case, no such benefit accrues to exchequer. - AT
Duty demand - revenue neutrality - since the goods were cleared to sister concern whatever duty payable and availed as credit to their own unit hence entire exercise would be revenue neutrality - if the ultimate exercise benefited the Revenue by collection of duty and in that case, no such benefit accrues to exchequer. - AT
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