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...
Restriction on import of Random Polished Marble Slabs - there is no whiff of any deliberate misrepresentation and the goods were in violation of Exim Policy only marginally as the CIF value worked out to be only marginally less than US $ 60 per SQM and that too due to monthly exchange rate changes notified vide Customs Notification after the appellant obtained quotation for the goods on 10.09.2011. - AT
Restriction on import of Random Polished Marble Slabs - there is no whiff of any deliberate misrepresentation and the goods were in violation of Exim Policy only marginally as the CIF value worked out to be only marginally less than US $ 60 per SQM and that too due to monthly exchange rate changes notified vide Customs Notification after the appellant obtained quotation for the goods on 10.09.2011. - AT
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