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...
Mutilation of Imported goods - No enquiries have been made overseas to find out the composition of the material. In that circumstances, the report of the chartered engineer is not acceptable, as he is not a metallurgical engineer, therefore, in the absence any evidence on record, the goods are to be cleared as scrap, therefore, there is no requirement of any mutilation.
Mutilation of Imported goods - No enquiries have been made overseas to find out the composition of the material. In that circumstances, the report of the chartered engineer is not acceptable, as he is not a metallurgical engineer, therefore, in the absence any evidence on record, the goods are to be cleared as scrap, therefore, there is no requirement of any mutilation.
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