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...
Applicability of Advance ruling - movement of goods through SEZ when it was not required - the advance ruling pronounced by the authority under Section 28-I shall be binding only on the applicant who had sought it. Therefore, the said advance ruling is not applicable to the present appellants - AT
Applicability of Advance ruling - movement of goods through SEZ when it was not required - the advance ruling pronounced by the authority under Section 28-I shall be binding only on the applicant who had sought it. Therefore, the said advance ruling is not applicable to the present appellants - AT
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