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 - input services utilised at the R&D centres of the appellant company and transferred to factory through input service distribution mechanism - the services in question have been admittedly used by the manufacturer indirectly in relation to manufacture of final dutiable products - credit allowed - AT
CENVAT credit - input services utilised at the R&D centres of the appellant company and transferred to factory through input service distribution mechanism - the services in question have been admittedly used by the manufacturer indirectly in relation to manufacture of final dutiable products - credit allowed - AT
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