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 distributor (ISD) - Since there is no allegation in the SCN as to the manner of distribution of credit as improper, it is not necessary to enter into such discussion - the disallowance of credit for the reason that appellant has not obtained ISD registration is unjustified and requires to be set aside - AT
CENVAT credit - input services distributor (ISD) - Since there is no allegation in the SCN as to the manner of distribution of credit as improper, it is not necessary to enter into such discussion - the disallowance of credit for the reason that appellant has not obtained ISD registration is unjustified and requires to be set aside - AT
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