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...
Allegation of illegal export - in the absence of any evidence to show that the money was remitted by way of Hawala, the case of over-invoicing could not be established by the Department - SC
Allegation of illegal export - in the absence of any evidence to show that the money was remitted by way of Hawala, the case of over-invoicing could not be established by the Department - SC
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