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...
Valuation - enhancement of value - All the documents submitted by the supplier are genuine and correct and considered as valid evidence. Therefore the same cannot be doubted - If it is so, it is established that the appellant had under-valued the goods - demand confirmed - AT
Valuation - enhancement of value - All the documents submitted by the supplier are genuine and correct and considered as valid evidence. Therefore the same cannot be doubted - If it is so, it is established that the appellant had under-valued the goods - demand confirmed - AT
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