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...
Claim of refund of export duty paid where goods could not be exported - Period of limitation - even though on payment of export duty, the Let Export Order (LEO) was received on 09.12.2011 - shipping bill was allowed to be cancelled only on 23.01.2013 and they had filed the refund claim on 10.05.2013. - Refund is beyond the normal period of limitation - AT
Claim of refund of export duty paid where goods could not be exported - Period of limitation - even though on payment of export duty, the Let Export Order (LEO) was received on 09.12.2011 - shipping bill was allowed to be cancelled only on 23.01.2013 and they had filed the refund claim on 10.05.2013. - Refund is beyond the normal period of limitation - AT
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