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...
Legality of adjustment of amount against the arrears out of the refund amount - at the time when the impugned demand with interest and penalty was adjusted from the refund, there was not only no stay against the recovery of the said dues nor was any stay application pending with regard thereto - adjustment confirmed - AT
Legality of adjustment of amount against the arrears out of the refund amount - at the time when the impugned demand with interest and penalty was adjusted from the refund, there was not only no stay against the recovery of the said dues nor was any stay application pending with regard thereto - adjustment confirmed - AT
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