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...
Period of limitation - in case duty was required to be paid on the strips, the appellant was entitled to avail credit of duty paid on the granules, which would have neutralized the entire demand on the strips - in this Revenue neutrally background, there could be no malafide on the part of the appellant to evade duty - AT
Period of limitation - in case duty was required to be paid on the strips, the appellant was entitled to avail credit of duty paid on the granules, which would have neutralized the entire demand on the strips - in this Revenue neutrally background, there could be no malafide on the part of the appellant to evade duty - AT
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