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...
Amendment of section 11A of Central Excise Act, 1944 - Recovery of duties not levied or not paid or short-levied or short-paid or erroneously refunded - the words “two years” for the words “one year” wherever they occur so as to increase the period of limitation in cases not involving fraud, suppression, etc. - Normal period of limitation for issuance of show cause notice to be increased from one year to two years.
Amendment of section 11A of Central Excise Act, 1944 - Recovery of duties not levied or not paid or short-levied or short-paid or erroneously refunded - the words “two years” for the words “one year” wherever they occur so as to increase the period of limitation in cases not involving fraud, suppression, etc. - Normal period of limitation for issuance of show cause notice to be increased from one year to two years.
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