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...
Refund claims - period of limitation where refund claim was filed electronically within prescribed time - They later submitted in physical form all these documents with Jurisdictional officer - refund cannot be rejected on the ground of time bar - AT
Refund claims - period of limitation where refund claim was filed electronically within prescribed time - They later submitted in physical form all these documents with Jurisdictional officer - refund cannot be rejected on the ground of time bar - AT
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