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 claim - Rule 5 of CCR, 2004 read with N/N. 27/2012 CE (NT) dated 08.06.2012 - Natural justice - rejection of refund without issuing a Show Cause Notice is highly harsh and violation of principles of natural justice. - AT
Refund claim - Rule 5 of CCR, 2004 read with N/N. 27/2012 CE (NT) dated 08.06.2012 - Natural justice - rejection of refund without issuing a Show Cause Notice is highly harsh and violation of principles of natural justice. - AT
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