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 - renting of immovable property - if a premises is only used for trading activities then the distribution of credit exclusively attributable to such unit will result in revenue loss to the Government. Thus, apparently there is no revenue neutrality in the instant case. - AT
CENVAT credit - input services - renting of immovable property - if a premises is only used for trading activities then the distribution of credit exclusively attributable to such unit will result in revenue loss to the Government. Thus, apparently there is no revenue neutrality in the instant case. - AT
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