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...
Valuation - enhancement of value - revenue neutrality - if duty had been paid by the appellants at the time of clearances, the same would have been available as cenvat credit in the hands of the buyer. Even of the appellants pay the differential duty, the same will be available as credit to the buyer. On this count also the issue is revenue neutral. - AT
Valuation - enhancement of value - revenue neutrality - if duty had been paid by the appellants at the time of clearances, the same would have been available as cenvat credit in the hands of the buyer. Even of the appellants pay the differential duty, the same will be available as credit to the buyer. On this count also the issue is revenue neutral. - AT
Note: It is a system-generated summary and is for quick reference only.