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...
Even for recovery of interest, no SCN is required As the statutory provisions mandate for payment of interest. The interest is piggyback of the duty demand, it goes hand in hand. Therefore, for the purpose of demand of interest no separate proceedings are required - AT
Even for recovery of interest, no SCN is required As the statutory provisions mandate for payment of interest. The interest is piggyback of the duty demand, it goes hand in hand. Therefore, for the purpose of demand of interest no separate proceedings are required - AT
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