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...
Refund claim - unjust enrichment - appellant had paid more duty at the time of clearance from the factory to depot, but have ultimately charged and realized less duty on the sale effected from the Depot - The refund has been denied simply based on presumptions, which is not tenable. - Refund allowed - AT
Refund claim - unjust enrichment - appellant had paid more duty at the time of clearance from the factory to depot, but have ultimately charged and realized less duty on the sale effected from the Depot - The refund has been denied simply based on presumptions, which is not tenable. - Refund allowed - AT
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