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...
Imposition of Anti Dumping Duty - new/unused pneumatic radial tyres with or without tubes and/or flap of rubber (including tubeless tyres) - For the injury analysis, the DA had examined all the mandatory parameters prescribed under the law. There is no need for segment wise analysis for OEM and replacement market. The categorical conclusion that dumped imports had caused material injury to the DI cannot be contested either in law or on fact. - AT
Imposition of Anti Dumping Duty - new/unused pneumatic radial tyres with or without tubes and/or flap of rubber (including tubeless tyres) - For the injury analysis, the DA had examined all the mandatory parameters prescribed under the law. There is no need for segment wise analysis for OEM and replacement market. The categorical conclusion that dumped imports had caused material injury to the DI cannot be contested either in law or on fact. - AT
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