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...
100% EOU - Refund claim - it cannot be said that Rule 5 refund is applicable only for exports of goods out of India and not for deemed exports supplies in India - deemed exports supplies are also eligible for refund u/r 5 - AT
100% EOU - Refund claim - it cannot be said that Rule 5 refund is applicable only for exports of goods out of India and not for deemed exports supplies in India - deemed exports supplies are also eligible for refund u/r 5 - AT
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