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...
Manufacture - so called activity of quality testing, branding and packing of the already manufactured goods will not be covered by note 6 of Section XVI of the Central Excise Tariff - the appellant is not engaged in the manufacturing of the goods, they are only doing trading activity of bought out goods. - AT
Manufacture - so called activity of quality testing, branding and packing of the already manufactured goods will not be covered by note 6 of Section XVI of the Central Excise Tariff - the appellant is not engaged in the manufacturing of the goods, they are only doing trading activity of bought out goods. - AT
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