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...
Imposition of penalty - when an assessee on his own ascertainment pays the amount of duty and interest thereon before issue of SCN, then SCN demanding the said amount cannot be served on the assessee - no penalty - AT
Imposition of penalty - when an assessee on his own ascertainment pays the amount of duty and interest thereon before issue of SCN, then SCN demanding the said amount cannot be served on the assessee - no penalty - AT
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