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...
Recovery of interest amount in respect of rebate claim, without issuance of SCN - once it has been held that the appellant is entitled for rebate claim, in absence of any specific provision for recovery of interest amount there-from, suo motu recovery of such amount by the Department is contrary to the statutory provisions
Recovery of interest amount in respect of rebate claim, without issuance of SCN - once it has been held that the appellant is entitled for rebate claim, in absence of any specific provision for recovery of interest amount there-from, suo motu recovery of such amount by the Department is contrary to the statutory provisions
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