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 - There is no concept of not passing on the duty to the ultimate consumer and as such, as the buyers have been passed on the benefit of reduction of duty, the same would satisfy the principles of unjust enrichment - refund allowed - AT
Refund - There is no concept of not passing on the duty to the ultimate consumer and as such, as the buyers have been passed on the benefit of reduction of duty, the same would satisfy the principles of unjust enrichment - refund allowed - AT
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