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...
Valuation - when the said import documents reveal that the goods have been procured from third party and the value declared is the value of the third party supplying the goods to Italian sister concern of the appellant, no question of rejection of transaction value arises - AT
Valuation - when the said import documents reveal that the goods have been procured from third party and the value declared is the value of the third party supplying the goods to Italian sister concern of the appellant, no question of rejection of transaction value arises - AT
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