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 of un-utilized CENVAT Credit - the assessee is not a registered Central Excise or Service Tax assessee and therefore cannot come under the purview of Cenvat Credit Rules, 2004 and therefore cannot claim refund under Rule 5 of the Cenvat Credit Rules, 2004 - AT
Refund of un-utilized CENVAT Credit - the assessee is not a registered Central Excise or Service Tax assessee and therefore cannot come under the purview of Cenvat Credit Rules, 2004 and therefore cannot claim refund under Rule 5 of the Cenvat Credit Rules, 2004 - AT
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