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...
Cenvat credit - Rule 16 of Central Excise Rules 2001/2002 - it is found that on 07.12.2005, the Appellant had received the rejected quantity of 577.11 MT at 23.45 hrs whereas the same was shown to have been cleared on the same day at 20.55 hrs. This leads to support the case of the Revenue and the Appellant could not rebut the charges of non-receipt by adducing sufficient evidences. - AT
Cenvat credit - Rule 16 of Central Excise Rules 2001/2002 - it is found that on 07.12.2005, the Appellant had received the rejected quantity of 577.11 MT at 23.45 hrs whereas the same was shown to have been cleared on the same day at 20.55 hrs. This leads to support the case of the Revenue and the Appellant could not rebut the charges of non-receipt by adducing sufficient evidences. - AT
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