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...
CENVAT credit - The availment of dual benefit of CENVAT Credit as well as income tax benefit on the inputs could be a critera for determination of income tax liability, however, the CENVAT Credit in absence of any stipulation under CCR 2004, cannot be denied to the Appellant - AT
CENVAT credit - The availment of dual benefit of CENVAT Credit as well as income tax benefit on the inputs could be a critera for determination of income tax liability, however, the CENVAT Credit in absence of any stipulation under CCR 2004, cannot be denied to the Appellant - AT
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