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...
Disallowance of Cenvat credit in excess of 20% - The appellants have reversed input of service credit taken on all common services and There is no other evidence to show certain other services were also common for which the appellants have not reversed the credit - Demand set aside - AT
Disallowance of Cenvat credit in excess of 20% - The appellants have reversed input of service credit taken on all common services and There is no other evidence to show certain other services were also common for which the appellants have not reversed the credit - Demand set aside - AT
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