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...
Rebate / refund claim - input stage credit - inputs used in the manufacture of their export goods - claim was rightly rejected on the grounds that the applicant has manufactured and exported the finished goods before filing the requisite declaration under the said notification and failed to fulfil the condition of the Notification No. 21/2004 -CE(NT) dated 06.09.2004. - CGOVT
Rebate / refund claim - input stage credit - inputs used in the manufacture of their export goods - claim was rightly rejected on the grounds that the applicant has manufactured and exported the finished goods before filing the requisite declaration under the said notification and failed to fulfil the condition of the Notification No. 21/2004 -CE(NT) dated 06.09.2004. - CGOVT
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